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programs, nor did he explain how he developed or procured those
materials. Petitioner did not offer any books or ledgers
relating to this business into the record. Petitioner did not
present the Court with a business plan or profit projections.
Other factors also weigh heavily against petitioner.
Petitioner does not have a college degree in education. When
asked for his credentials, petitioner responded that he was
qualified in the academic field because he had successfully
raised two children who are high academic achievers. Petitioner
did not maintain a separate checking account for the business but
paid his claimed business expenses from funds in his personal
account. Petitioner did not have a set schedule of time which he
devoted to the activity; rather, he worked on the activity
whenever he had available time. There is no indication that the
business had any assets that would appreciate in value.
An examination of the expenses claimed by petitioner lends
further support to our conclusion that petitioner lacked a profit
motive. Many of the expenses relate to travel and entertaining,
items that have elements of personal pleasure. Petitioner also
deducted monthly payments for his property on Lake Anna, a place
where petitioner took potential customers fishing. It also
appears that petitioner claimed numerous deductions for expendi-
tures that constitute nondeductible personal items. For
instance, petitioner deducted various costs related to his
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