Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 18

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               4.   Expectation That the Property Used in the Activity                
                    Would Appreciate in Value                                         
               The fact that a taxpayer expects assets used in an activity            
          to appreciate in value may indicate that the taxpayer has a                 
          profit objective.  Sec. 1.183-2(b)(4), Income Tax Regs.  The term           
          "profit" includes appreciation in the value of assets used in the           
          activity.  Id.  Petitioners expected the building to appreciate             
          in value.  This factor favors petitioners.                                  
               5.   Taxpayer's Success in Other Activities                            
               The fact that a taxpayer has previously engaged in similar             
          business activities and converted them from unprofitable to                 
          profitable may show that the taxpayer has a profit objective,               
          even though the activity is presently unprofitable.  Sec. 183-              
          2(b)(5), Income Tax Regs.  Petitioners had not previously engaged           
          in similar business activities.  This factor favors respondent.             
               6.   Taxpayer's History of Income or Losses                            
               A history of substantial losses may indicate that a taxpayer           
          did not conduct an activity for profit.  Golanty v. Commissioner,           
          72 T.C. 411 (1979), affd. without published opinion 647 F.2d 170            
          (9th Cir., 1981); sec. 1.183-2(b)(6), Income Tax Regs.  However,            
          a taxpayer may have a profit objective even when the activity has           
          a history of losses.  Bessenyey v. Commissioner, 45 T.C. 261, 274           
          (1965), affd. 379 F.2d 252 (2d Cir. 1967).  A series of losses              








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