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involved. No single factor controls. Sec. 1.183-2(b), Income
Tax Regs. The burden of proof is on petitioners. Welch v.
Helvering, 290 U.S. 111, 115 (1933).
Petitioners offered very little to support their contention
that they operated their antique store for profit in 1991 and
1992 or any other year. Mrs. Brockenbrough operated the store,
but did not testify, although she was present at trial. We infer
that petitioners have no stronger evidence available to support
their position about the store. Wichita Terminal Elevator Co. v.
Commissioner, 6 T.C. 1158 (1946), affd. 162 F.2d 513 (10th Cir.
1947).
1. Manner in Which the Activity is Conducted
Conducting an activity in a manner substantially similar to
comparable businesses which are profitable may indicate that a
taxpayer conducted the activity for profit. Engdahl v.
Commissioner, 72 T.C. 659, 666-667 (1979).
Petitioners offered little evidence about the business
activity of the store. There is no evidence that petitioners had
any business plan for the activity. Petitioners did not
advertise in 1991 or 1992. At trial, Mr. Brockenbrough did not
know what items petitioners sold or had in inventory during the
years in issue, and he admitted that he knew in 1991 that their
antique business could never be profitable. In the years in
issue, petitioners opened the store only part time and they left
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