Barry B. Bealor and Nancy L. Bealor, et al. - Page 45

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          Commissioner, 734 F.2d 7 (3d Cir. 1984), Kratsa v. Commissioner,            
          734 F.2d 6 (3d Cir. 1984), Leffel v. Commissioner, 734 F.2d 6 (3d           
          Cir. 1984), Hook v. Commissioner, 734 F.2d 5 (3d Cir. 1984)).               
               A determination of profit objective is to be made with                 
          reference to the actions and expectations of those individuals              
          who manage the affairs of the partnership.  Id. (citing Fox v.              
          Commissioner, supra at 1007-1008).                                          
               This Court has recently discussed the nature of this for-              
          profit test.  See Peat Oil & Gas Associates v. Commissioner, 100            
          T.C. 271 (1993), affd. sub nom. Ferguson v. Commissioner, 29                
          F.3d 98 (2d Cir. 1994).  In the cases at hand, whether the                  
          participants must have profit as their "primary purpose", or                
          whether it suffices that they have an "actual and honest" profit            
          objective, does not matter.  They have shown neither.                       
               The "subjective" test for business purpose--or profit                  
          objective--shares many characteristics with the "objective"                 
          economic substance test.  McCrary v. Commissioner, 92 T.C. 827,             
          844 (1989).  We have already discussed many of these                        
          characteristics in our consideration of economic substance; those           
          considerations apply with equal force to our conclusion that the            
          transactions at issue lacked business purpose and a profit                  
          objective.                                                                  
               The Court of Appeals for the Third Circuit has also                    
          explained:                                                                  
                    Whether the partnership has the requisite profit                  




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