Allen C. Chamberlin and Martha L. Chamberlin - Page 24

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               his own services rather than indirectly through the                    
               corporate enterprise * * *.                                            
          Id. at 202-203.  This Court has interpreted this language to mean           
          that, in order for a taxpayer to be engaged in a trade or                   
          business of promoting business ventures, he must undertake such             
          activity for compensation other than a normal investor’s return.            
          Such compensation must be in the form of a fee or commission or             
          from the sale of the corporation for a profit in the ordinary               
          course of business.  See Deely v. Commissioner, 73 T.C. 1081,               
          1093 (1980), supplemented by T.C. Memo. 1981-229.  Buying and               
          selling businesses for profit can constitute a trade or business            
          if the taxpayer shows that the entities were organized or                   
          acquired with the intent to make a quick and profitable sale                
          after each business has become established, rather than with a              
          view toward long-range investment gains.  See Id.                           
               In Farrar v. Commissioner, T.C. Memo. 1988-385, this Court             
          found that a taxpayer was engaged in the trade or business of               
          promoting business ventures.  The taxpayer in Farrar bought and             
          sold over 31 businesses, acquiring each one with the intent to              
          bring in his own management staff, rebuild the company, and then            
          sell it once the business became viable.  Of the three businesses           
          involved for which the taxpayer was claiming losses, the taxpayer           
          had a plan aimed at earning a profit through the sale of the                

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