Wilbur Kenneth Griesmer - Page 7

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               Section 183(c) defines an activity not engaged in for profit            
          as "any activity other than one with respect to which deductions             
          are allowable for the taxable year under section 162 or under                
          paragraph (1) or (2) of section 212."  Deductions are allowable              
          under section 162 or under section 212(1) or (2) only if the                 
          taxpayer is engaged in the activity with the "actual and honest              
          objective of making a profit."  See Ronnen v. Commissioner, 90               
          T.C. 74, 91 (1988); Dreicer v. Commissioner, 78 T.C. 642, 645                
          (1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983).                
               The existence of the requisite profit objective is a                    
          question of fact that must be decided on the basis of the entire             
          record.  See Benz v. Commissioner, 63 T.C. 375, 382 (1974).                  
               The regulations set forth a nonexhaustive list of factors               
          that may be considered in deciding whether a profit objective                
          exists.  These factors are: (1) The manner in which the taxpayer             
          carries on the activity; (2) the expertise of the taxpayer or his            
          advisers; (3) the time and effort expended by the taxpayer in                

          represented interest from bank accounts that may have been                   
          maintained in the name of The T.O.E. Co.  Accordingly, petitioner            
          did not derive any gross income from his meteorite and pyrite                
          collection activity because there was no "organizational and                 
          economic interrelationship" between that activity and the                    
          production of interest from bank accounts.  See sec. 1.183-                  
          1(d)(1), Income Tax Regs.  In other words, petitioner's meteorite            
          and pyrite collection activity and the production of interest                
          from bank accounts were not facets of the same "activity".                   
          Therefore, if petitioner's activity were not engaged in for                  
          profit, sec. 183(b) would not serve to allow any deductions.                 

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