- 9 - have maintained with respect to the activity. She had no set fees for her services, allowed customers to pay at their discretion, and made little or no effort to collect outstanding debts, notwithstanding the fact that she incurred substantial losses repeatedly over several years. The fact that petitioner failed to change her manner of operation in an effort to reverse her history of losses also supports respondent's adjustment. See id. Although a profit objective may exist despite a history of losses unaccompanied by any gains, see, e.g., Bessenyey v. Commissioner, supra at 273- 274, losses continuing beyond the period customarily necessary to make the operation profitable, if not explained, support the proposition that the activity is not engaged in for profit. Sec. 1.183-2(b)(6), Income Tax Regs. The record reflects that petitioner operated the activity in 1989 in a similar manner to its operation in prior years insofar as the general set up of the activity, the number of students tutored, the time petitioner devoted to the tutoring activity, etc. Petitioner did not change her operating methods from one year to the next in a manner consistent with an intent to improve profitability and did not adequately explain why she failed to do so. Sec. 1.183-2(b)(1), Income Tax Regs. Considering her history of losses, petitioner's practices of neither charging nor collecting fees from customers who werePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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