- 19 - 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 toPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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