- 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.
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