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service. Such an intent is not a sufficient profit motive for
purposes of section 162.
Accordingly, for the year 1983, respondent's allowance of
the expenses attributable to the operation of the charter boat
service only to the extent permitted by section 183 is sustained.
In addition, because petitioners have failed to substantiate any
such expenses deducted in 1984 and 1985, respondent's adjustments
disallowing the deductions for those years are likewise
sustained. Sec. 6001.
Because petitioners have failed to persuade us that the
charter boat service was conducted as a trade or business, it
follows that respondent's disallowances of the investment tax
credits for the years 1983 and 1984 must also be sustained, and
we so hold. Secs. 38, 48. It further follows that Hans Hammann
improperly claimed investment tax credit carrybacks to the years
1980 and 1981, and the deficiencies determined by respondent
against him for those years are sustained as well.
Cheryl Hammann's Condominium
The dispute on this issue arises primarily from respondent's
determination that petitioners used an improper currency
conversion rate in computing the depreciable basis of the
property. The conversion rate used by respondent in making her
adjustments is more favorable to petitioners than the average
conversion rate for the years involved. In any event,
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