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petitioner must establish that there was an activity which was
engaged in for profit within the meaning of section 183. Section
183(a) limits any deductions attributable to an activity of a
taxpayer not engaged in for profit except as provided in section
183(b). Section 183(b) provides that a deduction may be taken
where the taxpayer is not engaged in an activity for profit where
a deduction is otherwise allowable, to the extent that the gross
income from such activity exceeds the claimed deductions.
Section 183(c) defines an activity not engaged in for profit as
any with respect to which deductions would not be allowed under
section 162 or under paragraph (1) or (2) of section 212.
Expenses incurred in carrying on a trade or business are
allowable under section 162 if they are ordinary and necessary to
the conduct of that trade or business. Antonides v.
Commissioner, 91 T.C. 686, 693 (1988), affd. 893 F.2d 656 (4th
Cir. 1990). Section 212 allows deductions for expenses incurred
in connection with an activity engaged in for the production or
collection of income, or for the management, conservation, or
maintenance of property held for the production of income.
An activity will be considered as conducted for profit if
the facts and circumstances indicate the taxpayer entered into
the activity, or continued the activity, with the actual and
honest objective of making a profit. Antonides v. Commissioner,
supra; Dreicer v Commissioner, 78 T.C. 642, 645 (1982), affd.
without opinion 702 F.2d 1205 (D.C. Cir. 1983); Golanty v.
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