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operations. Respondent contends that petitioner did, in
contrast, maintain thorough business records for his other
businesses and that this contrast reveals a lack of a profit
motive in the treasure hunting operations. We agree that
petitioner's recordkeeping left something to be desired; we do
not, however, find that this negates petitioner's profit motive.
The treasure hunting activity was different from petitioner's
other businesses. Different recordkeeping methods are therefore
expected, and lack of recordkeeping is not determinative of
intent. Treasure hunting is not the type of business where
thorough records of gains and losses are necessary to a
successful operation. Cf. Farrell v. Commissioner, T.C. Memo.
1983-542. This type of activity is likely to generate only
expenditures with no income until a find is made at which time
the income will come in one lump sum. Therefore, we find that
petitioner's contemporaneous handwritten lists of expenses were
sufficient records for this type of activity.
More indicative of a profit motive is that petitioner did
not simply accept the first deal presented to him by
International Recoveries. Petitioner testified that the original
offer to join this venture was unsatisfactory and that he
negotiated for a higher percentage of any treasure that might be
recovered in addition to first being reimbursed for his expenses.
If petitioner had no expectation of profit, there would have been
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