- 31 - years in issue. Accordingly, we conclude that the frequency of occasional profits is a factor that favors respondent. 8. The Financial Status of the Taxpayer Substantial income from sources other than the activity, particularly if the losses from the activity generate substantial tax benefits, may indicate that the activity is not engaged in for profit. Sec. 1.183-2(b)(8), Income Tax Regs. Petitioners concede that, during the years in issue, they enjoyed a relatively high level of income from Mr. Abbene's employment with Pride Chemicals. Petitioners assert, however, that, without a profit motive, their income could not justify or sustain the type and size of expenditures that they incurred over the years. Respondent contends that petitioners' substantial income from their regular employment allowed them to continue operating Blue Ribbon despite the heavy losses incurred each year. We agree with respondent. Petitioners reported combined gross income in the amounts of $134,629, $112,136, and $110,245 for 1990, 1991, and 1992, respectively. Clearly, there is no benefit to losing money when the resulting tax savings represent less than 100 percent of the loss. Engdahl v. Commissioner, 72 T.C. at 670. Petitioners' substantial income, however, enabledPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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