Charles A. Ballard - Page 23

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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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