- 63 - activity for 1997 through 2000 and only nominal amounts thereafter. This factor is not favorable for Zane. 2. Taxpayer’s Expertise--Zane is a noted longtime expert in judging, showing, and breeding American Staffordshire Terriers and Staffordshire Bull Terriers. Accordingly, this factor favors Zane. 3. Time and Effort Spent Conducting the Activity--Zane testified that he spent an average of 10 to 12 hours per week on the dog breeding activity. He also testified that he spent 20 to 30 hours per week on the dairy farming, along with working full time (presumably at least 40 hours per week) at Beneco. Zane also testified about spending time in charitable activities. It appears that he was spread thin and that his estimates of hours may be overstated. Overall, however, this factor favors Zane. 4. Expectation That the Assets Will Appreciate in Value-- Zane believed that one of the dogs was worth $50,000, but he failed to corroborate his belief. In addition, he did not specify whether the dog was solely owned or coowned. If we were to assume that Zane’s belief was correct and that he was the sole owner, the $50,000 would not be sufficient to recoup the $275,000 in losses already incurred by 2001. Zane also had potential to earn revenue from insemination (breeding) and the sale of puppies. The difficultly here is the lack of documentation and/or corroboration supporting Zane’s contention. The incomePage: Previous 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 NextLast modified: March 27, 2008