- 15 - did for them. Indeed, Ms. Kahn could not recall how much peti- tioner charged her for automobile repairs. Consequently, we shall not rely on Mr. Goldberg's or Ms. Kahn's testimony to establish that petitioner engaged in his automobile repair activity for profit within the meaning of section 183. With respect to the 1993 receipt book, the 1992 and 1993 computer lists, and the automobile log, petitioner failed to testify about those documents, and there is no other evidence in the record to show when those documents were prepared and whether those documents are complete and accurate. Accordingly, on the instant record, we shall not rely on any of those documents in determining whether petitioner was engaged in his automobile repair activity for profit within the meaning of section 183. Nor is there any evidence in the record with respect to how many hours petitioner devoted to his automobile repair activity. Based on the salary of $55,464 that petitioner earned during 1993 from American Airlines, it appears that he worked full time for that company. It seems to us that petitioner could not have spent a significant amount of time on his automobile repair activity during 1993 if he was employed full time by American Airlines during that year. In further support of petitioners' argument that petitioner had the requisite profit objective under section 183 with respectPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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