B. Albert and Betty M. Holowinski - Page 9

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          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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