Dennis L. and Margaret J. Knudsen - Page 42




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         with a primary objective of realizing a profit.  We hold that                
         petitioners’ exotic animal breeding activity during the years in             
         issue was not an activity engaged in for profit within the                   
         meaning of section 183.                                                      
         III.  Respondent’s Alternative Position                                      
              Respondent argues that if we find that petitioners’ exotic              
         animal breeding activity was conducted for profit, petitioners’              
         claimed Schedule F expense deductions on their 2000 and 2001                 
         income tax returns should be reclassified as capital expenses and            
         depreciated, and certain expenses should be disallowed for lack              
         of substantiation.  Because we find that petitioners’ exotic                 
         animal breeding activity was not an activity engaged in for                  
         profit during 2000 and 2001, we need not address respondent’s                
         alternative position.                                                        
              To reflect the foregoing,                                               

                                                       Decision will be               
                                                 entered for respondent.              

















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