Kenneth C. & Becky J. Theisen - Page 6

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          F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs.               
          The taxpayer's motive to make a profit must be analyzed by                  
          looking at all the surrounding objective facts.  Dreicer v.                 
          Commissioner, supra at 645.  These facts are given greater weight           
          than to petitioners' mere statement of intent.  Dreicer v.                  
          Commissioner, supra.                                                        
               Section 1.183-2(b), Income Tax Regs., provides a                       
          nonexclusive list of relevant factors to be considered in                   
          deciding whether an activity is engaged in for profit.  These               
          factors are: (1) The manner in which the taxpayer carries on the            
          activity; (2) the expertise of the taxpayer or his advisors; (3)            
          the time and effort expended by the taxpayer in carrying on the             
          activity; (4) the expectation that assets used in the activity              
          may appreciate in value; (5) the success of the taxpayer in                 
          carrying on similar or dissimilar activities; (6) the taxpayer's            
          history of income or losses with respect to the activity; (7) the           
          amount of occasional profits, if any, which are earned; (8) the             
          financial status of the taxpayer; and (9) elements of personal              
          pleasure or recreation.  Sec. 1.183-2(b), Income Tax Regs.  These           
          factors are not applicable or appropriate in every case.                    
          Abramson v. Commissioner, 86 T.C. 360, 371 (1986).                          
               After a review of the record, we conclude that respondent              
          has carried the burden of proving that petitioners lacked the               
          requisite profit objective within the meaning of section 183 in             

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