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activity that consumed only a modest portion of petitioner's work
week.
Petitioner has also failed to demonstrate any expertise in
the securities industry. Petitioner does not have a license to
trade securities or any formal training in investing. He has no
employment history in the brokerage business or in any aspect of
the securities and investment consulting field. He has shown no
experience in the area of his alleged consulting activity.
Petitioner had substantial income from sources other than
the investment consulting activity. During the year at issue,
petitioner was employed full time as an engineer. In 1996,
petitioner received wages from his employment as an engineer in
the amount of $41,537.
Lastly, petitioner has not provided us with evidence that
demonstrates that he has a history of generating income from this
investment consulting activity. Accordingly, based upon the
above factors we hold that petitioner did not engage in the
consulting activity for profit. On the contrary, the record, and
particularly the substantial claimed expenses, indicates that the
activity, such as it was, was conducted for the purpose of
supporting a claim to offset Schedule C losses against wages
earned in an entirely separate employment activity.
Our finding that petitioner did not engage in the consulting
activity for profit does not end our inquiry. For 1996,
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