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activity year after year. Petitioner’s parents provided the use
of a residence and a barn where the activity was conducted.
Petitioner’s wife’s wages earned met living expenses, which
allowed petitioner to maintain the activity in question.
9. The Elements of Personal Pleasure or Recreation
Involved in the Activity
The record clearly demonstrates that petitioner has been
strongly interested in the field of metal mining and refining
since he was a youth. It was this interest that motivated
petitioner to get involved in the metal mining and refining
activity. Petitioner testified that the aspects of that
particular activity were "interesting" to him. He noted that
this activity was not immediately profitable. We believe that
engaging in this activity provided significant pleasure to
petitioner.
Hard work alone is not enough to establish a profit-seeking
objective. Feldman v. Commissioner, T.C. Memo. 1986-287. While
the metal mining and refining activity is hard physical work and
may not seem pleasurable to some, petitioner enjoyed this
activity and lifestyle. In addition, petitioner had a propensity
to pursue these activities, which he found pleasurable such as
research. He would pursue less desirable income-producing
activities only to the extent that it would serve to finance his
enjoyable non-income-producing pursuits.
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