- 7 - of occasional profits, if any, which are earned; (8) the financial status of the taxpayer; and (9) elements of personal pleasure or recreation. These factors are not applicable or appropriate in every case. Abramson v. Commissioner, 86 T.C. 360, 371 (1986). Petitioner carried on his music activity in a nonbusiness like manner. Petitioner claimed various expenses including car and truck expenses, depreciation, and supplies. Petitioner admitted that he failed to maintain any books or records, or a separate business bank account. There also is no evidence that petitioner carried on the activity in a manner similar to other activities of the same nature which are profitable. Sec. 1.183- 2(b)(1), Income Tax Regs. Although petitioner testified that he attempted to promote his music activity by handing out compact discs, on which he was listed as a contributing guitarist, to some people in the music industry, petitioner did little else to promote or advertise his availability as a musician for hire. Indeed, petitioner admitted that he did not advertise in the local telephone directory, distribute flyers, or obtain business cards. Petitioner was not a member of any musicians' union. Petitioner made no reasonable efforts to gain recognition as a musician playing Christian music for hire.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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