- 5 - of section 162(a) generally depends upon whether the taxpayer's purpose for engaging in the activity is for income or profit, and whether the activity is conducted with continuity and regularity. Commissioner v. Groetzinger, 480 U.S. 23, 35 (1987). Section 183(a) disallows any deductions attributable to "activities not engaged in for profit" except as provided in section 183(b). Respondent argues that petitioners' research activity was not engaged in for profit and any claimed deductions are subject to the limitations of section 183(b). Furthermore, respondent contends that petitioners must substantiate any deductions claimed. Rule 142(a). Whether a taxpayer engaged in an activity with the primary purpose of making a profit is a question of fact. Dreicer v. Commissioner, 78 T.C. 642, 644-645 (1982), affd. without published opinion 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183- 2(a), Income Tax Regs. While a reasonable expectation of profit is not required, taxpayer's profit objective must be bona fide. Taube v. Commissioner, 88 T.C. 464, 478-479 (1987). In making this determination, the Court gives more weight to objective facts than to a taxpayer's mere statement of intent. Dreicer v. Commissioner, supra at 645; sec. 1.183-2(a), Income Tax Regs. Section 1.183-2(b), Income Tax Regs., provides a nonexclusive list of factors to be considered in determining whether an activity is engaged in for profit. The factors include: (1) The manner in which the taxpayer carried on thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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