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(9) any elements of personal pleasure or recreation. No single
factor, nor simple numerical majority of factors, is controlling.
See Cannon v. Commissioner, 949 F.2d 345, 350 (10th Cir. 1991),
affg. T.C. Memo. 1990-148.
From what is in the record, we have great reservations
whether there was even a trade or business activity here, to say
nothing of a trade or business entered into for profit. There
are no records or other indicia of a business operation.
Furthermore, from petitioner’s brief description of the activity,
the deductions claimed (e.g., repairs, utilities, etc.) would
seem not to have any nexus with that activity. The “mortgage”
expense was for the rent of petitioner’s lodging in Alexandria
where he was employed. This is nothing more than a disingenuous
subterfuge for deducting personal living expenses. Cf. sec. 262.
Even if this activity were a trade or business, the history
of losses belies any notion that it was operated for profit.
While a person may start out with a bona fide expectation of
profit, even if it is unreasonable, there is a time when, in
light of the recurring losses, the bona fides of that expectation
must cease. See Filios v. Commissioner, 224 F.3d 16 (1st Cir.
2000), affg. T.C. Memo. 1999-92. Ten years is time enough. This
is particularly pertinent here where there is nothing in the
record to reasonably suggest that the activity, as petitioner
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