G. Dastgir and Mary A. Qureshi - Page 12

          petitioners are not entitled to the claimed investment tax credit           
          for 1984.                                                                   
               b.  Profit Objective                                                   
               In order to qualify for depreciation and other expense                 
          deductions with respect to the container, petitioners must                  
          demonstrate that the container was used in a trade or business or           
          was held for the production of income.  Secs. 162, 167, 212.                
               To be entitled to a depreciation deduction, petitioner must            
          prove that he had “an actual and honest objective of making a               
          profit.”   Dreicer v. Commissioner, 78 T.C. 642, 646 (1982), affd.          
          without opinion 702 F.2d 1205 (D.C. Cir. 1983). For this purpose,           
          “profit” means economic profit, independent of tax savings.                 
          Surloff v. Commissioner, 81 T.C. 210, 233 (1983).  There is no              
          requirement that a reasonable expectation of profit exist.  Elliott         
          v. Commissioner, 90 T.C. 960, 970 (1988), affd. without published           
          opinion 899 F.2d 18 (9th Cir. 1990).   The determination of whether         
          an activity is engaged in for profit is made by reference to                
          objective standards, taking into account all the facts and                  
          circumstances of each case.  Brannen v. Commissioner, 78 T.C. 471,          
          506 (1982), affd. 722 F.2d 695 (11th Cir. 1984).  Greater weight is         
          given to the objective facts than to the taxpayer’s own statements          
          of intent.  Sec. 1.183-2(b), Income Tax Regs.9  A taxpayer bears            

               9    Sec. 1.183-2(b), Income Tax Regs., sets forth a                   
          nonexclusive list of factors used in determining whether an                 
          activity is engaged in for profit.  The regulation lists nine               

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