Bernard Michael Reed - Page 6

          continued it, with the bona fide objective of making a profit, as           
          judged by all the facts and circumstances.  Taube v.                        
          Commissioner, 88 T.C. 464, 478-479 (1987); Poast v. Commissioner,           
          T.C. Memo. 1994-399; sec. 1.183-2(a), Income Tax Regs.                      
               The regulations set forth nine non-exclusive factors for               
          consideration in determining whether an activity is engaged in              
          for profit.  Sec. 1.183-2(b), Income Tax Regs.  These factors               
          are:  (1) The manner in which the taxpayer carries on the                   
          activity; (2) the expertise of the taxpayer or his advisers; (3)            
          the time and effort expended by the taxpayer in carrying on the             
          activity; (4) the expectation that assets used in the activity              
          may appreciate in value; (5) the success of the taxpayer in                 
          carrying on other activities; (6) the taxpayer's history of                 
          income or losses with respect to the activity; (7) the amount of            
          occasional profit, if any, which is earned; (8) the financial               
          status of the taxpayer; and (9) whether elements of personal                
          pleasure or recreation are involved.  Furthermore, if a taxpayer            
          has substantial income from sources other than the activity in              
          question, it may be an indication that the activity is not                  
          engaged in for profit, particularly if the losses from the                  
          activity generate substantial tax benefits.  Sec. 1.183-2(b)(8),            
          Income Tax Regs.                                                            
               No single factor is controlling.  Abramson v. Commissioner,            
          86 T.C. 360, 371 (1986); Golanty v. Commissioner, 72 T.C. 411,              
          426 (1979), affd. without published opinion 647 F.2d 170 (9th               

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