- 10 - 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 hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011