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constituted a bona fide business venture entered into for profit
under section 183 and also because respondent did not concede
that the undisputed expenditures were deductible business
expenses.
Discussion
Section 183(a) provides that if an activity engaged in by an
individual is not engaged in for profit, no deduction
attributable to such activity shall be allowed, except as
provided in section 183(b). In the case of an activity not
engaged in for profit, section 183(b)(1) allows a deduction for
expenses that are otherwise deductible without regard to whether
the activity is engaged in for profit. Section 183(b)(2) allows
a deduction for expenses that would be deductible only if the
activity were engaged in for profit, but only to the extent that
the total gross income derived from the activity exceeds the
deductions allowed by section 183(b)(1).
An “activity not engaged in for profit” is any activity for
which deductions are not allowable under section 162 or under
paragraph (1) or (2) of section 212. Sec. 183(c). The profit
motive required by section 183 is the same as the profit motive
required by sections 162 and 212. See Antonides v. Commissioner,
893 F.2d 656, 659 (4th Cir. 1990), affg. 91 T.C. 686 (1988); sec.
1.183-2(a), Income Tax Regs.
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