Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 19

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          during the initial stage of an activity does not necessarily                
          indicate that the activity was not conducted for profit.  Engdahl           
          v. Commissioner, supra at 669; sec. 1.183-2(b)(6), Income Tax               
          Regs.                                                                       
               The antique store was not profitable during any of the 4               
          years it was open.  Petitioners did little or nothing to sell the           
          building and inventory during the 2 years after they knew the               
          business could not be profitable.  They liquidated their                    
          inventory at an auction in 1992.  They did not explain why they             
          waited that long or show that their inventory was difficult to              
          liquidate.  During the period of delay, petitioners continued to            
          depreciate the building and incur expenses for mortgage,                    
          interest, repairs, maintenance, and utilities for the building.             
          For 1991, they reported gross receipts of $1,885, cost of goods             
          sold of $1,802, and expenses of $11,035.  For 1992, they reported           
          gross receipts of $2,589, cost of goods sold of $4,743, and                 
          expenses of $7,496.                                                         
               This factor favors respondent.                                         
               7.   Amount of Occasional Profits, if Any                              
               Small occasional profits with large continuous losses do not           
          establish that the taxpayer had a profit objective.  Sec. 1.183-            
          2(b)(7), Income Tax Regs.  This factor generally applies to                 









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