Barry B. Bealor and Nancy L. Bealor, et al. - Page 44

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          service providers are deductible under section 162(a)(1), which             
          allows a deduction for "expenses incurred in carrying on any                
          trade or business, including * * * a reasonable allowance for               
          salaries or other compensation for personal services actually               
          rendered".                                                                  
               In Commissioner v. Groetzinger, 480 U.S. 23 (1987), the                
          Supreme Court said that in order for a taxpayer to be in a trade            
          or business, within the meaning of section 162, the "primary                
          purpose" for engaging in the activity must be for profit.  The              
          Supreme Court stated:                                                       
               the taxpayer must be involved in the activity with                     
               continuity and regularity and * * * the taxpayer's                     
               primary purpose for engaging in the activity must be                   
               for income or profit. * * *  [Id. at 35.]                              
               The Court of Appeals for the Third Circuit has explained:              
          "It is well established that in order to take a deduction for               
          expenses incurred in carrying out a trade or business the                   
          taxpayer must have entered into the venture with the primary and            
          predominant purpose and objective of making a profit."  Simon v.            
          Commissioner, 830 F.2d 499, 500 (3d Cir. 1987), affg. T.C. Memo.            
          1986-156.  "While a reasonable expectation of profit is not                 
          essential, the profit motive must be bona fide."  Id. (citing Fox           
          v. Commissioner, 80 T.C. 972, 1006 (1983), affd. without                    
          published opinion 742 F.2d 1441 (2d Cir. 1984), affd. sub nom.              
          Barnard v. Commissioner, 731 F.2d 230 (4th Cir. 1984), Zemel v.             
          Commissioner, 734 F.2d 9 (3d Cir. 1984), Rosenblatt v.                      





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