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field appears to pay large amounts of money to those who succeed
in it and "an opportunity to earn a substantial ultimate profit
in a highly speculative venture is ordinarily sufficient to
indicate that the activity is engaged in for profit even though
losses or only occasional small profits are actually generated."
Sec. 1.183-2(b)(7), Income Tax Regs. Likewise, we are not
inclined to give much weight to the seventh factor, the amount of
occasional profits, if any, that are earned, because only the
first 2 years of petitioner's writing activity are in issue.
Respondent argues that the next factor, the financial status
of the taxpayer, negates petitioner's profit motive because his
independent sources of income are such that the writing activity
generated tax benefits for him. We disagree with respondent. We
do not believe that petitioner's income was so high as to make
tax savings his primary objective. We also do not find it
unlikely that petitioner, aware of his upcoming retirement and of
the change in his pre and postretirement income, would choose to
embark on something new. No doubt the fact that he began his
writing activity during his preretirement years contributed to
his ability to try his hand at it. Nothing in the record,
however, indicates that writing then became a hobby for him.
Rather, we find it clear from his testimony and from the
objective evidence that petitioner was a writer who desired
success and who intended to make a profit from his work.
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