- 16 - Martin v. Commissioner, 50 T.C. 341, 364 (1968); Rand v. Commissioner, 34 T.C. 1146, 1149-1150 (1960). We also note that during 1990 petitioner reported substantial income from sources other than his activity with respect to the Cloudia. See sec. 1.183-2(b)(8), Income Tax Regs. He reported gross income from his legal practice in the amount of $157,391, and a net profit from that activity in the amount of $78,253. In addition, petitioner reported capital gains of $75,139 from the sale of 2709 NW 12th and 1809 Carey Place, two of his rental properties, ordinary income of $3,612 from the sale of those two rental properties, and a loss of $3,456 from the sale of the “Edmond Lot”. In sum, for the 1990 tax year, petitioner realized income of $153,548 from sources other than the rental of the Cloudia. Finally, the record suggests that petitioner derived personal enjoyment from his activity with respect to the Cloudia. See sec. 1.183-2(b)(9), Income Tax Regs. Petitioner testified that ever since he was young he wanted to be involved with boats, and that the first time he stepped onto the Cloudia he “felt like Errol Flynn”. Petitioner also testified that he had built two other sailboats, one which he sold, and one which he retained for recreational purposes.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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