Hugh T. Brown, Jr., and Kristi L. Brown - Page 21




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          his mining expeditions were substantial.  In a recent                       
          consideration of mining for gold and precious metals in the                 
          southwestern United States, this Court found that such gold                 
          mining is “an extremely laborious activity that requires                    
          substantial time, energy, and financial support.  Mining also               
          entails numerous health risks, including heat prostration in the            
          summer months, silicosis, and cyanide poisoning.”  Tinnell v.               
          Commissioner, supra.  In light of the hardships and serious                 
          dangers involved, we are convinced that any personal pleasure or            
          recreational aspects that petitioner might have enjoyed while               
          mining for gold were secondary.  Moreover, some component of                
          personal pleasure does not negate a bona fide profit objective.             
          “[A] business will not be turned into a hobby merely because the            
          owner finds it pleasurable; suffering has never been made a                 
          prerequisite to deductibility.  ‘Success in business is largely             
          obtained by pleasurable interest therein.’”  Jackson v.                     
          Commissioner, 59 T.C. 312, 317 (1972) (quoting Wilson v. Eisner,            
          282 F. 38, 42 (2d Cir. 1922)); see also sec. 1.183-2(b)(9),                 
          Income Tax Regs.  This factor favors petitioners’ position.                 
                                     Conclusion                                       
               In this case we are satisfied that, despite the substantial            
          losses over an extended period, during the years in issue                   
          petitioners had a bona fide profit objective.  This conclusion is           
          far from unique.  See Engdahl v. Commissioner, 72 T.C. 659 (1979)           






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