- 11 - petitioners were not engaged in their horse-related activities for profit within the meaning of section 183(a) and disallowed the loss for 1992. OPINION The issue to be resolved is whether petitioners' horse- related activities4 constituted an "activity not engaged in for profit" within the meaning of section 183. Section 183(a) generally disallows a deduction for activities not engaged in for profit except as provided in section 183(b). Section 183(b)(1) allows deductions for an activity which are otherwise allowable regardless of profit objective. Section 183(b)(2) allows those deductions which would be allowable if the activity were engaged in for profit, but only to the extent that gross income attributable to the activity exceeds the deductions permitted by section 183(b)(1). Section 183(c) defines "activity not engaged in for profit" as "any activity other than one with respect to which deductions are allowable for the taxable year under section 162 or under paragraph (1) or (2) of section 212." Deductions are allowable under section 162 with respect to activities for which the taxpayer has demonstrated that his "primary purpose for engaging in the activity * * * [was] for income or profit." Commissioner v. Groetzinger, 480 U.S. 23, 35 4 The parties have treated all of petitioners' horse-related activities as a single activity for purposes of sec. 183. See sec. 1.183-1(d)(1), Income Tax Regs.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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