- 24 - 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 thePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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