Arlan L. Rower and Sandra M. Howard - Page 15

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          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 respect           







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