Kenneth E. Perry and Mary A. Hofer - Page 15

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             an individual or an S corporation no deduction attributable              
             to an activity which is not engaged for profit is allowed                
             except as provided in section 183(b).  Section 183(b)(1)                 
             allows the 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 the activity were 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 under paragraph (1) or (2) of section 212."               
             The test for determining whether an activity is engaged in               
             for profit is whether the individual is engaged in the                   
             activity with "the actual and honest objective of making a               
             profit".  See Dreicer v. Commissioner, 78 T.C. 642, 645                  
             (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,              
             he must have entered into or continued the activity with a               
             bona fide objective of doing so.  See Keanini v. Commis-                 




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