Harland and Shirley Stonecipher - Page 12




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          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 taxpayer’s financial status; and             
          (9) whether elements of personal pleasure or recreation are                 
          involved.  See sec. 1.183-2(b), Income Tax Regs.; see also Cannon           
          v. Commissioner, supra at 348-349.                                          
               The taxpayer's expectation of profit need not be reasonable            
          but must be in good faith.  See Golanty v. Commissioner, 72 T.C.            
          411, 425-426 (1979), affd. without published opinion 647 F.2d 170           
          (9th Cir. 1981); Allen v. Commissioner, supra at 33; sec.                   
          1.183-2(a), Income Tax Regs.  In determining whether an activity            
          is engaged in for profit, greater weight is given to objective              
          factors than to a taxpayer's mere statement of intent.  See                 
          Anderson v. Commissioner, 62 F.3d 1266, 1274 n.16 (10th Cir.                
          1995), affg. T.C. Memo. 1993-607; Cannon v. Commissioner, supra             
          at 351 n.8; sec. 1.183-2(a), Income Tax Regs.                               
               Although no one factor is conclusive, see sec. 1.183-2(b),             
          Income Tax Regs., a record of substantial losses over many years            
          and the unlikelihood of achieving a profit are indicative that an           
          activity is not engaged in for profit, see Hildebrand v.                    
          Commissioner, supra at 1027; Cannon v. Commissioner, supra at               
          352; Golanty v. Commissioner, supra at 426; sec. 1.183-2(b)(6),             
          Income Tax Regs.                                                            








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