Richard Jackson Sleeper - Page 8

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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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