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artist activity since its inception in 1984. Indeed, in addition
to the 1988 through 1991 years at issue here, petitioner also
reported losses for every year during the 1984 through 1987 and
1992 through 1993 periods. Petitioner has presented no evidence
of a change in operating methods to reverse his uninterrupted
history of losses, tending to indicate that he is content to
sustain those losses for purely personal reasons. Breckenridge
v. Commissioner, T.C. Memo. 1983-66.
The large unabated expenditures, the absence even at this
late date of any concrete business plans to reverse the losses,
and the manner in which petitioner conducted his artist activity
lead to the conclusion that this was not an activity engaged in
for profit. Eppler v. Commissioner, 58 T.C. 691, 697 (1972),
affd. without published opinion 486 F.2d 1406 (7th Cir. 1973).
Although the mere fact that a taxpayer derives personal
pleasure from a particular activity does not mean that he or she
lacks a profit objective with respect thereto, the presence of
personal motives may indicate that the activity is not engaged in
for profit. Glenn v. Commissioner, T.C. Memo. 1995-399. This is
especially true where there are recreational or other personal
elements involved. Sec. 1.183-2(b)(9), Income Tax Regs. As this
Court has stated, with respect to this factor:
Unquestionably, an enterprise is no less a "business"
because the entrepreneur gets satisfaction from his
work; however, where the possibility for profit is
small (given all the other factors) and the possibility
for gratification is substantial, it is clear that the
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