Harm De Boer - Page 22

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          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 expenses            



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