- 38 - expanding their already existing commercial banking activities, and not preopening expenses of new businesses. On the other hand in Hardy v. Commissioner, supra, this Court concluded that the taxpayer’s intent to buy and thereafter to own and manage large commercial hotel and motel properties was unrelated to the taxpayer’s part-time work managing rental homes. We believe that the situation in the instant case is more like a rental real estate manager beginning a new business as a manager and owner of hotels and motels, than it is like commercial banks expanding into the credit card industry. Laney worked as a computer programming consultant. In or around 1977 Laney began to do computer consulting for several pharmaceutical companies. Laney designed integrated computer systems for these companies that could communicate with other computer systems. His work for these companies was performed either at their facilities or at his home office. Laney’s consulting work consisted of providing a service; it did not include rental of space or ownership of real property. In the case of R.K., however, Laney’s plan was to profit from the rental of cage space. He expected to offer his consulting services to the R.K. researching entities, but none of those entities would be required to use his consulting services. Petitioners called Clement C. Darrow II (hereinafter sometimes referred to as Darrow), as an expert witness, both toPage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
Last modified: May 25, 2011