Steven Carl Akerson - Page 8

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            v. Commissioner, supra at 46; Golanty v. Commissioner, supra at                              
            426; sec. 1.183-2(a), Income Tax Regs.                                                       
                  The regulations promulgated under section 183 provide a                                
            nonexclusive list of factors to be considered in determining                                 
            whether an activity is engaged in for profit.  Sec. 1.183-2(b),                              
            Income Tax Regs.  No single factor is determinative, Keanini v.                              
            Commissioner, supra at 47; Taube v. Commissioner, 88 T.C. 464,                               
            479-480 (1987); sec. 1.183-2(b), Income Tax Regs.  Taking those                              
            factors into account, and based on the record as a whole, we                                 
            conclude that the resort activity was an activity entered into                               
            for profit.                                                                                  
                  C.  Petitioner Had An Objective To Make a Profit                                       
                  The regulations provide:  "Although a reasonable expectation                           
            of profit is not required, the facts and circumstances must                                  
            indicate that the taxpayer entered into the activity * * * with                              
            the objective of making a profit."  Sec. 1.183-2(a), Income Tax                              
            Regs.  Respondent contends that petitioner did not have a profit                             
            objective with his resort activity and that he was engaged in the                            
            activity only to shelter income.  We disagree.                                               
                  When petitioner bought Playa de los Vivos, he was in the                               
            process of selling Heart, phasing out his employment at Heart,                               
            and trying to find a source of income to replace the salary Heart                            
            paid him.  At the same time that petitioner bought the resort, he                            
            bought a home on a different piece of property than the resort.                              
            Additionally, petitioner kept accurate books and records of the                              




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