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making a profit because such sponsorship was not financially
rewarding.
Petitioner argues that a taxpayer may be engaged in an
activity for profit even if losses are sustained for a number of
years. See, e.g., Keanini v. Commissioner, 94 T.C. 41 (1990);
Kimbrough v. Commissioner, T.C. Memo. 1988-185. However, as
stated above, whether a taxpayer is engaged in an activity for
profit depends upon the specific facts and circumstances of the
individual case. Based on our analysis of the factors, we
conclude that petitioner did not engage in tournament fishing
with the requisite profit objective. See Connolly v.
Commissioner, T.C. Memo. 1994-218, affd. without published
opinion 58 F.3d 637 (5th Cir. 1995). Respondent is sustained on
this issue.
To reflect the foregoing,
Decision will be entered
for respondent.
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