Thomas B. Drummond - Page 29

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          contributing to petitioner's decision to abandon his alleged                
          business activities involving the sale of artwork.                          
               On the instant record, we sustain respondent's determination           
          that the gain that petitioner realized from the sale of the                 
          drawing in question is long-term capital gain.                              
          Petitioner's Horse Activity and Cattle Activity                             
               Section 183--In General                                                
               Section 183(a) generally limits the amount of expenses that            
          a taxpayer may deduct with respect to an activity "not engaged in           
          for profit" to the deductions provided in section 183(b).                   
          Section 183(b)(1) provides that deductions that would be allow-             
          able without regard to whether such activity is engaged in for              
          profit are to be allowed.  Section 183(b)(2) further provides               
          that deductions which would be allowable only if such activity is           
          engaged in for profit are to be allowed, but only to the extent             
          that the gross income derived from such activity for the taxable            
          year exceeds the deductions allowable under section 183(b)(1).              
          An activity is "not engaged in for profit" if it is an activity             
          other than one with respect to which deductions are allowable for           
          the taxable year under section 162 or section 212(1) or (2).                
          Sec. 183(c).                                                                
               In determining whether an activity is engaged in for profit,           
          the taxpayer must show that he or she engaged in the activity               
          with an actual and honest objective of making a profit.  E.g.,              
          Hulter v. Commissioner, 91 T.C. 371, 392 (1988); Dreicer v.                 





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