8 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.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011