William Herbert Whitehurst, III and Carla Cherlene Whitehurst - Page 13




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          winnings offered were significant.  While Mrs. Whitehurst did not           
          earn a profit with respect to the activity, opportunity for                 
          profit existed.  These facts support the claim that she entered             
          into the bowling activity with a profit objective.                          
               f.  Financial Status of the Taxpayer                                   
               The fact that the taxpayer does not have substantial income            
          from sources other than the activity may indicate that the                  
          activity is engaged in for profit.  Sec. 1.183-2(b)(8), Income              
          Tax Regs.  Substantial income from other sources may indicate               
          that the activity is not engaged in for profit especially if                
          there are personal or recreational elements in the activity.  Id.           
               Petitioners’ combined wages totaled $81,104 in 1997, $87,667           
          in 1998, and $89,764 in 1999.  Although Mrs. Whitehurst explained           
          that she and her husband did not earn as much income as they                
          wanted, their combined wage income for each of the 3 years at               
          issue is not insignificant.  Given that personal and recreational           
          elements are involved in the bowling activity, as we discuss                
          below, this factor does not support an intent to profit.  See id.           
               g.  Elements of Personal Pleasure                                      
               The presence of personal motives in carrying on an activity            
          may indicate that the activity is not engaged in for profit,                
          especially where there are recreational or personal elements                
          involved.  Sec. 1.183-2(b)(9), Income Tax Regs.  The fact that              
          the taxpayer derives personal pleasure from engaging in the                 






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