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Commissioner, T.C. Memo. 1983-542. We find petitioner's
marketing efforts more indicative of his profit objective.
Petitioner held himself out as a drilling contractor during the
relevant period by listing his business in the telephone
directory. Also, petitioner submitted proposals to provide
drilling services to oil and construction companies. Petitioner
actively sought contracts to use the drill rig commercially.
Finally, we consider petitioner's financial status.
Petitioner is not a wealthy individual whose unprofitable
drilling activity would suggest an effort to shelter unrelated
income through deliberate losses. While substantial income from
sources other than the activity may indicate that the activity is
not engaged in for profit, the fact that the taxpayer does not
have substantial income from sources other than the activity
tends to indicate that an activity is engaged in for profit.
Sec. 1.183-2(b)(8), Income Tax Regs. The legislative history of
the Tax Reform Act of 1969, Pub. L. 91-172, 83 Stat. 487
discloses a particular concern about wealthy individuals
attempting to generate paper losses for the purpose of sheltering
unrelated income. See H. Rept. 91-413 (1969), 1969-3 C.B. 200,
244-245. We have no such concerns with respect to petitioner,
particularly with respect to the year 1986, when he had no wage
income. We do not believe that petitioner’s intention in 1986,
when he earned no wages, was to generate a large net operating
loss that he could carry to a later period. Petitioner's
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