- 55 - Rance was generally knowledgeable about cutting horses and had experience in riding, breeding, and caring for these animals. Rance consulted with numerous experts; however, he did not detail the specific advice received or how he employed that advice in the activity. He sought no professional advice on the economics of the cutting horse activity. He did, however, seek advice about the tax aspects and ways to avoid classification of the activity as a hobby. Rance did seek guidance and advice from others, but he failed to explain how the advice he obtained was used or how it assisted in the attempt to seek profits from the activity. However, this factor favors Rance and LaRhea. 3. Time and Effort Spent in Conducting the Activity--The fact that the taxpayer devotes much of his personal time and effort to carrying on an activity, particularly if the activity does not have substantial personal or recreational aspects, may indicate an intention to derive a profit. Sec. 1.183-2(b)(3), Income Tax Regs. Rance spent 8 to 10 hours a week on this activity. His involvement with cutting horses provided a recreational benefit. The record is sparse, however, on the specifics of Rance’s involvement in this activity. Accordingly, this factor favors respondent’s determination. 4. Expectation That the Assets Will Appreciate in Value-- The taxpayer’s expectation that the assets used in the activity may appreciate in value may, under certain circumstances,Page: Previous 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 NextLast modified: March 27, 2008