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profit from his lending activity would defy common sense. The
Court will not reiterate all the facts and circumstances in
support but finds from the record that petitioner lent money with
the intent to make a profit. See Hirsch v. Commissioner, 315
F.2d 731, 737 (9th Cir. 1963), affg. T.C. Memo. 1961-256; Golanty
v. Commissioner, 72 T.C. 411, 426 (1979), affd. without published
opinion 647 F.2d 170 (9th Cir. 1981); sec. 1.183-2(a), Income Tax
Regs.
Determining whether petitioner's lending money for profit
rose to the level of a trade or business is a somewhat more
difficult inquiry. That petitioner was a chemistry professor
does not preclude him from also being in another trade or
business at the same time. See Curphey v. Commissioner, 73 T.C.
766, 775-776 (1980). But petitioner must show not only that his
primary purpose for engaging in the activity was for income or
profit, but also that he engaged in the activity with "continuity
and regularity". Groetzinger v. Commissioner, 480 U.S. 23, 35
(1987). In order to be considered a trade or business,
petitioner's lending activity must be extensively carried on.
Imel v. Commissioner, 61 T.C. 318, 323 (1973); Rollins v.
Commissioner, 32 T.C. 604, 613 (1959), affd. 276 F.2d 368 (4th
Cir. 1960); see also Barrish v. Commissioner, 31 T.C. 1280, 1286
(1959).
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