Paula L. Wilson - Page 8
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law enforcement careers, devoted considerable time to, and
handled all material aspects of, the activity. Sec. 1.183-
2(b)(3), Income Tax Regs. (stating that the fact that a taxpayer
devotes substantial personal time and effort to carrying on an
activity may indicate an intention to derive a profit).
Petitioners expected their farm and herd to appreciate.
Furthermore, petitioners devoted all of their savings from their
law enforcement salaries to the activity. They are hardworking,
diligent, and levelheaded. We do not believe that they would
squander their hard-earned money on an extravagant hobby.
The fact that the taxpayers do not have substantial income
or capital from sources other than the activity may indicate that
the activity is engaged in for profit. See sec. 1.183-2(b)(8),
Income Tax Regs. Although petitioners suffered several setbacks
(e.g., the injuries suffered by Ms. Wilson, the death of Scotch N
Lark, etc.) that prevented them from making a profit, they
actually and honestly believed that their future earnings and
profit would be substantial.
Contentions we have not addressed are irrelevant, moot, or
To reflect the foregoing,
Decisions will be entered
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Last modified: November 10, 2007