- 24 - 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011