George F. Walker - Page 10

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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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