Robert and Joyce Dirkse - Page 13

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          taxpayer in carrying on the activity; (4) the expectation that              
          assets used in the activity may appreciate in value; (5) the                
          success of the taxpayer in carrying on other similar or dissimilar          
          activities; (6) the taxpayer’s history of income or losses with             
          respect to the activity; (7) the amount of occasional profits, if           
          any, which are earned; (8) the financial status of the taxpayer;            
          and (9) whether elements of personal pleasure or recreation exist.          
          No single factor is necessarily relevant or dispositive; rather,            
          the facts and circumstances of the case ultimately control.  See            
          Keanini v. Commissioner, 94 T.C. 41, 47 (1990).  Further, the               
          determination of a taxpayer’s profit motive is made on a yearly             
          basis.  See Commissioner v. Sunnen, 333 U.S. 591, 598 (1948).               
               We now apply each of these factors to the facts in this case.3         
               1.  Manner of Carrying on the Activity                                 
               The fact that a taxpayer carries on an activity in a                   
          businesslike manner and maintains complete and accurate books and           
          records may indicate that the activity was engaged in for profit.           
          See Engdahl v. Commissioner, 72 T.C. 659, 666 (1979); sec. 1.183-           
          2(b)(1), Income Tax Regs.  Adapting new techniques and abandoning           
          methods that are economically inefficient may also support the              

               3    The record does not reveal whether petitioners ever               
          engaged in other similar or dissimilar activities.  Thus, we find           
          a discussion of petitioners’ success in these activities to be              

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