- 13 - Commissioner, supra at 46; Golanty v. Commissioner, supra at 426; sec. 1.183-2(a), Income Tax Regs. Section 1.183-2(b), Income Tax Regs., provides a nonexclusive list of factors to be considered in determining whether an activity is engaged in for profit. No single factor is determinative. Keanini v. Commissioner, supra at 47; Taube v. Commissioner, 88 T.C. 464, 479-480 (1987); sec. 1.183-2(b), Income Tax Regs. Taking into account the factors set forth in section 1.183- 2(b), Income Tax Regs., and based on the record as a whole, we conclude that the charter activity was not an activity entered into for profit, and we have so found. C. Petitioner Had No Objective To Make a Profit The regulations provide that “Although a reasonable expectation of profit is not required, the facts and circumstances must indicate that the taxpayer entered into the activity * * * with the objective of making a profit.” Sec. 1.183-2(a), Income Tax Regs. We conclude that, although petitioner certainly would have liked Ballard Marine to make a profit, that was not his objective in organizing and operating Ballard Marine. In determining petitioner’s objective in organizing and operating Ballard Marine, we have the benefit of neither a statement of corporate purpose (in Ballard Marine’s articles of incorporation) nor a formal business plan. Nevertheless,Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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