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unrelated activities also may indicate a profit objective.
Daugherty v. Commissioner, T.C. Memo. 1983-188. A taxpayer who
was able to start a business and turn it into a relatively large
and profitable enterprise through the taxpayer’s diligence,
initiative, foresight, and other qualities that generally lead to
success in other business activities has shown evidence of a
profit objective. Id.
Petitioner is an experienced businessman. During the years
at issue, petitioner was the senior vice president and chief
financial officer of the bank. Petitioner’s activities in his
position included serving on the loan committee, which required
petitioner to assess the needs and attributes of businesses
applying for loans and to oversee the bank’s financial planning,
budgeting, and statistical analysis functions. Petitioner also
served on the board of directors of the bank, helping to make
important business decisions and oversee the bank’s direction.
Petitioner’s success in the banking field indicates that he has
considerable business skills. See id.
6. The Taxpayer’s History of Income or Loss With Respect
to the Activity
We next examine petitioner’s history of income or loss with
respect to the activity. A history of substantial losses may
indicate that the taxpayer did not conduct the activity for
profit. Golanty v. Commissioner, 72 T.C. 411, 427 (1979), affd.
without published opinion 647 F.2d 170 (9th Cir. 1981); sec.
1.183-2(b)(6), Income Tax Regs. Losses during the initial or
startup stage of an activity do not necessarily indicate,
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