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this income was reduced by the $13,217 which he spent in support
of Benjamin's amateur motocross racing activity. Furthermore, as
more fully discussed, infra, at factor 9, the activity was both
personal and recreational with respect to petitioner and his son:
petitioner’s actions were as consistent, if not more consistent,
with one who wishes to participate in an activity with his son as
with one who wishes to supplement his already substantial income.
This factor favors respondent.
9. Elements of Personal Pleasure or Recreation.
The presence of personal motives in carrying on an activity,
especially where there are recreational or personal elements
involved, may indicate that the activity is not engaged in for
profit. See sec. 1.183-2(b)(9), Income Tax Regs. Profit need
not be the only objective, however, and personal motives may
coexist with an actual and honest intent to derive a profit. See
id.
Benjamin was unable to earn any potential profit for several
years after the year in issue. Furthermore, any potential profit
was dependent upon many unknown variables involved with beginning
a professional career–-such as Benjamin’s future size, abilities,
and even desire to continue pursuing the activity into his late
teen and early adult years. Finally, the motocross racing
activity was inherently recreational and was conducted as an
activity to be shared by father and son. Considering these
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