- 42 - 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.Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42Last modified: March 27, 2008