Sheriel L. Sexcius - Page 7

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                Our consideration of respondent's adjustment with respect to                 
          petitioner's Schedule C deductions begins with an examination of                   
          whether petitioner conducted her tutoring activity with the                        
          intent to make a profit.  Absent an intent to make a profit,                       
          petitioner's tutoring activity could not be considered a trade or                  
          business within the meaning of section 162.  Commissioner v.                       
          Groetzinger, 480 U.S. 23 (1987).                                                   
                The test for determining whether a taxpayer conducted an                     
          activity for profit is whether he or she entered into, or                          
          continued, the activity with the actual or honest objective of                     
          making a profit.  Dreicer v. Commissioner, 78 T.C. 642, 644-645                    
          (1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983);                      
          sec. 1.183-2(a), Income Tax Regs.  The taxpayer's expectation of                   
          profit need not be reasonable, but the profit objective must be                    
          bona fide, as judged by all facts and circumstances.  Dreicer v.                   
          Commissioner, supra at 645; Golanty v. Commissioner, 72 T.C. 411,                  
          426 (1979), affd. without published opinion 647 F.2d 170 (9th                      
          Cir. 1981); Bessenyey v. Commissioner, 45 T.C. 261, 274 (1965),                    
          affd. 379 F.2d 252 (2d Cir. 1967).                                                 
                Whether petitioner engaged in her tutoring activity with the                 
          requisite profit objective must be determined on a year-by-year                    
          basis from the facts and circumstances of the case.  Golanty v.                    
          Commissioner, supra at 426; sec. 1.183-2(a) and (b), Income Tax                    
          Regs.  More weight is given to objective facts than to                             






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