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 the
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