Walter C Demattia and Elizabeth J. Crouse - Page 24

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               The presence of these facts in isolation is not dispositive.           
          "[T]he fact that the taxpayer derives personal pleasure from                
          engaging in the activity is not sufficient to cause the activity            
          to be classified as not engaged in for profit if the activity is            
          in fact engaged in for profit as evidenced by other factors".               
          Sec. 1.183-2(b)(9), Income Tax Regs. (Emphasis added).  However,            
          in this case, other factors do not indicate the presence of a               
          profit motive.  Accordingly, this factor supports respondent's              
          determinations.                                                             
               10.  Conclusion                                                        
               Based on our careful review of the record, and our                     
          evaluation of the nine aforementioned factors, we conclude that             
          petitioners did not conduct their sponsorship activity with an              
          "actual and honest" objective of making a profit.11                         
               We have considered all other arguments made by petitioners             
          and found them to be either irrelevant or without merit.                    
                         To reflect the foregoing,                                    
                                                  Decisions will be entered           
                                             for respondent as to the                 
                                             deficiencies in tax, and in              
                                             accordance with respondent's             


               11  Having found that petitioners' golf sponsorship activity           
          was an "activity not engaged in for profit" within the meaning of           
          sec. 183, we need not address the issue of whether certain                  
          deductions disallowed by respondent are allowable.                          




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