Commissioner, 949 F.2d at 352; Golanty v. Commissioner, 72 T.C. at 426-427. Petitioners generated substantial losses from their rental activity, mostly from depreciation, and were able to shelter their medical income with the losses. (8) The financial status of the taxpayer. Because of petitioners' income from their medical practices, they obtained significant tax benefit from the rental activity losses. (9) The presence of elements of personal pleasure or recreation. Mr. Hilliard went to the property occasionally to do repairs; however, petitioners used the property for personal trips and recreational purposes. We hold that petitioners' Tahoe rental activity was not engaged in for profit within the meaning of section 183(c). V. Automobile Expenses During the years in issue, petitioners owned four automobiles. Mrs. Hilliard drove the Mercedes, which was used to commute to work, to drive between different work locations, and for personal errands. Her offices were in Oakland, California, for all of the years in issue and in San Ramon, California, for 3 months during 1986. The commute from Mrs. Hilliard's residence to her office was 8 to 9 miles, and the distance between the San Ramon and Oakland offices was 15 miles. Mrs. Hilliard made early morning rounds in two hospitals: one which was about 3 miles from her Oakland office, and the other was less than 1 mile from her Oakland office. The majority of her patients were at thePage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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