- 9 -
years in issue. Indeed, assuming petitioners liquidated all of
the inventory they purchased during the years in issue and that
they were able to purchase it at 40 percent of the hypothetical
sale value, the ensuing gross profit would not even cover the
cost of their traveling expenses. Stated more bluntly,
petitioners' traveling expenses were so grossly in excess of
their total sales that petitioners had no prospect of ever
turning a profit.4
Furthermore, we find it telling that for subsequent years
petitioners have not even prepared a profit and loss statement.
Surely, if a person were concerned with making a profit, she or
he would be interested in whether in fact there was or would be a
profit or loss from the activity.
Finally, petitioners admittedly derived personal pleasure
from antique hunting and possibly from displaying their more
valuable pieces of antique glassware in their home. We are
cognizant of the fact that there is no general prohibition on
pursuing a business that one enjoys. See Larson v. Commissioner,
T.C. Memo. 1991-99. We are also cognizant that the Federal fisc
should not help underwrite personal pursuits. See Stanley v.
Commissioner, T.C. Memo. 1980-217.
In sum, after considering all the relevant factors, we
conclude that, while petitioners may have intended to earn a
4 We note that petitioners' travel records showed that of the
34 days traveling in 1993, 10 were spent in the Dallas/Fort Worth
area where petitioners' daughter lived.
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