Rodney W. Taras and Linda K. Taras - Page 10

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               Deductions are allowed under section 162 for the ordinary              
          and necessary expenses of carrying on an activity which                     
          constitutes the taxpayer's trade or business.  Deductions are               
          allowed under section 212 for expenses paid or incurred in                  
          connection with an activity engaged in for the production or                
          collection of income, or for the management, conservation, or               
          maintenance of property held for the production of income.  With            
          respect to either section, the taxpayer must demonstrate a profit           
          objective for the activities in order to deduct associated                  
          expenses.  See Agro Science Co. v. Commissioner, 934 F.2d 573,              
          576 (5th Cir. 1991), affg. T.C. Memo. 1989-687; Antonides v.                
          Commissioner, 893 F.2d 656, 659 (4th Cir. 1990), affg. 91 T.C.              
          686 (1988); Allen v. Commissioner, 72 T.C. 28, 33 (1979);                   
          Jasionowski v. Commissioner, 66 T.C. 312, 320-322 (1976); Rand v.           
          Commissioner, 34 T.C. 1146, 1149 (1960); sec. 1.183-2(a), Income            
          Tax Regs.  While a reasonable expectation of profit is not                  
          required, a taxpayer's profit motive must be bona fide.  Simon v.           
          Commissioner, 830 F.2d 499, 500 (3d Cir. 1987), affg. T.C. Memo.            
          1986-156.                                                                   
               Respondent argues that for purposes of section 183, a                  
          taxpayer must prove that profit was the primary purpose for                 
          engaging in the activity.  In Simon v. Commissioner, supra at               
          500, the Court of Appeals for the Third Circuit, the court to               
          which this case is appealable, stated:                                      






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