The petitioner was a full time insurance professional and also engaged in various real estate ventures from his home base in North Carolina. He got involved in cattle breeding with an individual located (at least part of the time) in Indiana. The cattle breeding venture resulted in numerous breached contracts, unpaid bills and promissory notes and unregistered genetic lines of cattle. The cattle breeding business was not operated in a business-like manner. In addition, the cattle breeding venture showed four consecutive years of losses while he was showing a substantial increase in income from this insurance and real estate businesses. The court determined that IRS prevailed under the I.R.C. Sec. 183 tests and petitioner's cattle breeding venture was deemed to be conducted without a profit intent. Gardner v. Comr., T.C. Memo. 148.