- 22 - The taxpayer may hope to derive a profit from an activity, and may intend that, even if no profit is derived from current operations, an overall profit will result when appreciation in the value of property used in the activity is realized. Sec. 1.183-2(b)(4), Income Tax Regs. Although petitioner's work on his drill rig was a source of personal satisfaction, a drill rig would hardly qualify as a recreational vehicle. Profit objective is to be determined on an objective basis. Engdahl v. Commissioner, 72 T.C. 659, 666 (1979). A drill rig drills holes in the ground for purposes of starting wells or foundations of improvements to real property. Thus, we do not characterize a drill rig as a recreational vehicle, as we would a motorcycle or sports car. Section 1.212- 1(b), Income Tax Regs., provides in relevant part, that the term "income" includes income that the taxpayer may realize in subsequent taxable years, and is not confined to recurring income, but applies as well to gains from the disposition of property. We thus find that, during 1991, petitioner's drill rig was property held for the production of income within the meaning of section 212. Petitioner maintains that his drill rig has a present value of $500,000 to $750,000. The value of a capital asset is a function of the stream of income that it can produce, and petitioner has failed to produce any revenue through the use of the drill rig. Nevertheless, we are persuaded that the expensesPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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