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no significant use of the boat for personal purposes. Even
granting that Slawek is relevant, we do not find that there is
substantial authority supporting petitioner’s position. The
following cases are an example of cases involving facts similar
to those at hand, but in which the Court found no profit
objective: Ward v. Commissioner, T.C. Memo. 1987-215; Blake v.
Commissioner, T.C. Memo. 1981-579, affd. 697 F.2d 473 (2d Cir.
1982); Lyon v. Commissioner, T.C. Memo. 1977-239. We find that
the authority supporting petitioner’s deduction of the section
183 losses is insubstantial.
Petitioner has made no argument with respect to adequate
disclosure or substantial authority in connection with those
adjustments that petitioner has conceded. We thus conclude that
petitioner concedes that section 6661(b)(2)(B) is inapplicable to
those adjustments, and we so find. Accordingly, we sustain
respondent’s determination of an addition to tax under section
6661 except to the extent necessary to take account of
concessions made by respondent.
Decision will be entered
under Rule 155.
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