Walter C Demattia and Elizabeth J. Crouse - Page 10

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          account, and more weight may be given to some factors than to               
          others.  Glenn v. Commissioner, T.C. Memo. 1995-399, affd.                  
          without published opinion 103 F.3d 129 (6th Cir. 1996); Sec.                
          1.183-2(b), Income Tax Regs.  None of these factors is                      
          dispositive.  Golanty v. Commissioner, 72 T.C. 411, 426 (1979),             
          affd. without published opinion 647 F.2d 170 (9th Cir. 1981).               
               Dr. DeMattia testified that he had an honest objective of              
          making a profit from the golf sponsorship agreements with his               
          son.  He further testified that he believed that he would make              
          millions of dollars as a result of the sponsorship agreements.              
          We give greater weight to objective factors than to Dr.                     
          DeMattia's uncorroborated testimony as to his intent in                     
          determining whether he had the requisite profit objective.                  
          Keanini v. Commissioner, 94 T.C. 41, 46 (1990); Dreicer v.                  
          Commissioner, supra at 645; sec. 1.183-2(a), Income Tax Regs.               
               1.  Manner in Which the Activity is Conducted                          
               That the taxpayer carried on the activity in a businesslike            
          manner and maintained complete and accurate records may indicate            
          that the activity is engaged in for profit.  Sec. 1.183-2(b)(1),            
          Income Tax Regs.  Additionally, a change in operating procedures,           
          adoption of new techniques, or the abandonment of unprofitable              
          methods indicates a profit motive.  Id.                                     
               Among other things, respondent argues that the following               
          facts establish that Dr. DeMattia failed to conduct the activity            





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