James C. Vallette and Arleen R. Vallette - Page 14

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          and his co-workers in the activity have always been his wife and            
          their immediate family, none of whom were paid.  As this Court              
          observed, 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 latter possibility                
               constitutes the primary motivation for the activity.                   
               [Burger v. Commissioner, T.C. Memo. 1985-523, affd. 809 F.2d           
               355 (7th Cir. 1987).]                                                  
               This factor favors respondent's determination.                         
               10.  Conclusion                                                        
               Based on our discussion above, we conclude that petitioners            
          operated their activity without an "actual and honest" objective            
          of making a profit.  The activity provided petitioners with                 
          satisfaction, and any income derived therefrom served only as an            
          added bonus to them.                                                        
               We have considered all arguments made by petitioners for a             
          contrary holding and, to the extent not discussed above, have               
          found them to be without merit.  To reflect concessions,                    
                                             Decision will be entered                 
                                        under Rule 155.                               

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