- 10 - V. Taxpayers' Financial Status The fact that the taxpayer does not have substantial income or capital from sources other than the activity may indicate that the activity is engaged in for profit. Sec. 1.183-2(b)(8), Income Tax Regs. Petitioners' financial status strongly suggests that petitioners engaged in the Activity for profit. In 1988, petitioners earned wage income of $33,008 and net income of $16,334 from the carpet cleaning business. In 1989, Mr. Dawson earned wage income of $28,618 from his job at the railroad and net income of $7,803 from the carpet cleaning business. To earn this income, Mr. Dawson worked long hours at two arduous jobs. Mr. Dawson's testimony indicated that he was a shrewd, hardworking, diligent, and levelheaded businessman. We do not believe that he would squander his hard-earned money on an extravagant hobby. VI. Amount of Profits The amount of profits earned in the activity, when compared to the amount of losses incurred, the amount of the investment, and the value of the assets in use, may indicate a profit objective. Sec. 1.183-2(b)(7), Income Tax Regs. Petitioners did not earn a profit on the Activity. The opportunity to earn substantial profits in a highly speculative venture, however, is ordinarily sufficient to indicate that the activity is engaged in for profit even though only losses are produced. Id. Further,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011