8
not determinative; greater weight is given to objective factors
rather than to the taxpayer's mere statement of intent. Engdahl
v. Commissioner, 72 T.C. 659, 666 (1979). Moreover, section 262
generally precludes a taxpayer from deducting personal, living,
or family expenses.
Based on the record, we find that petitioner lacked the
requisite profit objective in carrying on his brokerage
activities. Petitioner contends that he carried on his brokerage
activities in a regular and continuous manner; however, the
evidence he presented at trial indicates otherwise. Petitioner
introduced 12 documents, including several form letters from
petitioner while he was associated with BLA and IBEX with names
of various companies inserted in the blanks and dated as far back
as September 10, 1982, letters regarding petitioner's membership
in a broker association, subscriptions to newsletters, lists of
potential buyers, and letters to petitioner regarding his status
as a "valued referral source" for Guaranty Acceptance Capital
Corporation (GACC) dated in late 1989 or 1990. Petitioner also
introduced a brochure for K.R. Bradbury & Associates and a
receipt for the printing thereof dated September 15, 1988.
These documents do not demonstrate a regular and continuous
pursuit of brokerage activities for profit during the years at
issue. Most of the letters are dated prior to 1988, none of the
documents are dated in 1988, and it appears that the only
document dated during 1989 was the letter to petitioner regarding
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