Arlan L. Rower and Sandra M. Howard - Page 16

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          to petitioner's automobile repair activity, petitioners contend             
          that there was a "profit trend" with respect to that activity.              
          Although not altogether clear, it appears that petitioners base             
          that contention on the premise that the amount of the losses that           
          petitioners claimed for 1992, 1993, 1994, and 1995 decreased from           
          year to year.  We note initially that the respective losses that            
          petitioners claimed for 1994 and 1995 represented petitioner's              
          allocable share of certain partnership losses, which presumably             
          were less than the total losses for that partnership.  More                 
          importantly, we reject petitioners' contention that the losses              
          which they claimed for the years 1992, 1993, 1994, and 1995                 
          establish a "profit trend" for petitioner's automobile repair               
          activity.                                                                   
               Based on our review of the entire record before us, we find            
          that petitioners have failed to demonstrate that petitioner was             
          engaged in his automobile repair activity with an actual and                
          honest objective of making a profit.  The objective facts estab-            
          lished by that record indicate that most of the factors enumer-             
          ated in the regulations under section 183 favor respondent. We              
          further find based on the present record that petitioners have              
          failed to prove that the expenses that they claimed in their 1993           
          Schedule C and their 1993 amended Schedule C (1) were paid or               
          incurred during 1993 and/or (2) were ordinary and necessary to              







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