Deborah Joyce Windisch - Page 15

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          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.                                                         




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