- 15 - activity, but claimed expenses of $20,122. For 1991, the parties agree that petitioner received approximately $2,864 from her photography activity, but claimed expenses of $19,230. For 1992, petitioner received approximately $1,711 from her photography activity, but claimed expenses of $17,636. While losses incurred during the early stage of an activity might not necessarily indicate that the activity is not engaged in for profit, continued losses after the period customarily required to bring an operation to profitability, if not explainable by ordinary business reverses, may indicate that the activity is not engaged in for profit. Sec. 1.183-2(b)(6), Income Tax Regs. Petitioner has not attempted to establish the period customarily required to bring a photography business to profitability, nor has she offered adequate reasons for the substantial continuing losses experienced by her photography activity. Given the circumstances of the instant case, petitioner's claimed losses indicate that the photography activity was not engaged in for profit. Considering petitioner's financial status, it appears to us that the income derived from petitioner's other employment enabled her to continue to engage in her photography activity in the manner in which she conducted it, indicating that the photography activity was not engaged in for profit. Engdahl v. Commissioner, 72 T.C. 659, 670 (1979). Petitioner's losses offset in large part the income she derived from other sources.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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