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stated that a taxpayer's engaging in full-time employment in
addition to conducting a profit-seeking activity can be a
positive factor illustrating the taxpayer's motivation, rather
than a negative element as often argued by respondent when a
taxpayer devotes time to other activities. See Dickson v.
Commissioner, T.C. Memo. 1986-182. In the instant case, the
Court views petitioner's full-time employment history as a
complement to the activities of BRVC rather than a negative
factor. The Court is satisfied that petitioner expended
sufficient time and efforts on BRVC during the years at issue and
prior and subsequent thereto to favor a profit motive in
connection therewith.
Respondent contends that the fourth factor, i.e., the
expectation that the assets used in the activity may appreciate
in value, weighs against petitioner. Respondent argues that BRVC
owned no assets other than a computer, fax machine, two VCR's,
and some sporting equipment, all of which were depreciating
assets. Thus, respondent argues, since petitioner had no
prospect of realizing any appreciation of BRVC assets, this is an
indication that petitioner lacked a profit objective. The Court
finds this argument to be unpersuasive. There exist many
business activities the nature of which do not require and are
not conducive to the ownership of property that may appreciate in
value, and BRVC was one such activity. The Court finds that the
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