Martin and Marion Abbene - Page 21

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                  3.    The Time and Effort Expended by the Taxpayer in                                  
                        Carrying On 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.                                                              
                  Petitioners contend that Mr. Abbene devoted a considerable                             
            amount of time and effort to the operation of Blue Ribbon which                              
            is indicative of a profit motive.  Respondent argues that                                    
            petitioners failed to establish the amount of time that Mr.                                  
            Abbene devoted to the operation of Blue Ribbon or that he                                    
            employed competent and qualified persons to oversee the day-to-                              
            day operations of Blue Ribbon in his absence.  See sec. 1.183-                               
            2(b)(3), Income Tax Regs.  Respondent contends that Mr. Abbene's                             
            responsibilities to his employer, Pride Chemicals, would                                     
            necessarily limit the amount of time that he was able to devote                              
            to Blue Ribbon's activities.                                                                 
                  Although the record does not support a finding of the exact                            
            amount of time that Mr. Abbene spent working for Blue Ribbon, we                             
            are convinced that it was substantial.  The record indicates that                            
            Mr. Abbene and Elena managed all aspects of Blue Ribbon's                                    
            operations.  Mr. Abbene devoted his evenings, weekends, and much                             








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