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in for profit" within the meaning of section 183. Section
183(a) provides that no deduction attributable to an
activity which is not engaged in for profit is allowable
except as provided in section 183(b). Section 183(b)(1)
allows all deductions which would be allowable without
regard to whether the activity is engaged in for profit.
Section 183(b)(2) allows a deduction equal to the amount of
the deductions that would be allowable for the taxable year
if such activity was engaged in for profit, but only to the
extent the gross income derived from the activity exceeds
the deductions allowable under section 183(b)(1).
Section 183(c) defines "activity not engaged in for
profit" as "any activity other than one with respect to
which deductions are allowable for the taxable year under
section 162 or paragraph (1) or (2) of section 212." The
key requirement for deductibility under sections 162 and
212(1) and (2) is that the taxpayer be engaged in the
activity with an actual and honest objective of making a
profit. See Dreicer v. Commissioner, 78 T.C. 642, 644
(1982), affd. without published opinion 702 F.2d 1205
(D.C. Cir. 1983); Brannen v. Commissioner, 78 T.C. 471,
502 (1982), affd. 722 F.2d 695 (11th Cir. 1984); Allen v.
Commissioner, 72 T.C. 28, 33 (1979). Although a taxpayer
need not have a reasonable expectation of earning a profit,
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