Harm De Boer - Page 17

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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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