- 17 - 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'sPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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