- 11 - 1984 through 1993. Mr. Flanagin's history of losses indicates a lack of a profit motive. E. Petitioners' Financial Status Substantial income from sources other than the activity in question, particularly if the activity's losses generate substantial tax benefits, may indicate that the activity is not engaged in for profit. See sec. 1.183-2(b)(8), Income Tax Regs. In 1992 and 1993, Mr. Flanagin had nonsoftware activity income of at least $156,773 and $63,838, respectively. Mr. Flanagin could afford to operate the software development activity as a hobby. This factor indicates a lack of profit objective. F. Other Factors Mr. Flanagin knew that the useful life of the Z-100 was nearing its end. Petitioners argue, however, that Mr. Flanagin's work relating to the Z-100 was laying the foundation for developing PC-compatible software. At the trial, Mr. Flanagin testified that he had no evidence to support this contention. Even if Mr. Flanagin had been attempting to move into the PC- compatible market, the aforementioned factors still weigh against petitioners. G. Conclusion After reviewing the entire record, we conclude that Mr. Flanagin did not engage in the software development activity withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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