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Petitioners thereby received substantial tax benefits from the
sponsorship activity. This factor supports respondent's
determinations.
9. Elements of Personal Pleasure
Although the mere fact that a taxpayer derives personal
pleasure from a particular activity does not mean that he or she
lacks a profit intent with respect thereto, the presence of
personal motives may indicate that the activity is not engaged in
for profit. This is especially true where there are recreational
elements involved. Sec. 1.183-2(b)(9), Income Tax Regs.
Respondent argues that the evidence establishes that Dr.
DeMattia's primary purpose in entering into the sponsorship
agreements was to assist Dr. DeMattia's son in pursuing a
professional golf career and not an honest objective of making a
profit within the meaning of section 183(a). Respondent argues
that both personal motives and a recreational element are present
in this case. As for personal motives, Dr. DeMattia derived some
degree of personal satisfaction in trying to assist Constant in
achieving his professional golfing goal, and the arrangement gave
Dr. DeMattia the opportunity to spend additional time with both
his father and his son. As to the recreational element of the
activity, Dr. DeMattia has been an avid golfer for more than
20 years and particularly enjoys playing golf with his son.
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