- 12 - Rather, petitioner appears to have sought long-term returns from his ownership interests, which is the hallmark of the investor. Deely v. Commissioner, supra. Although petitioner was actively involved in the management of the apartment building, there is no evidence he was directly compensated for his services. Moreover, it does not appear that he planned to sell the apartment building once it became established; rather, he sold it as a result of his divorce proceedings. Similarly, petitioner apparently sought a return from Cinevision in the form of enhanced value of his investment, rather than from direct compensation for his services to the corporation. Petitioner, moreover, reported the income or loss connected with Cinevision as passive income or loss on his 1987 through 1989 returns. Petitioner’s activities with respect to Cinevision, which consisted of meetings with its management to discuss its difficulties, appear no different from those of an investor seeking to protect his investment. As we discuss below, we reach the same conclusion with respect to petitioner’s activities in connection with Color Trick. The record is also devoid of evidence of other indicia of a business of promoting corporations, such as the active seeking out of opportunities to promote corporations, advertising, the maintenance of a separate office or books of account for such a business, or the preparation of statements of profit and lossPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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