- 27 -                                         
          compared to prior years' expenses.  This illustrates an obvious             
          effort by petitioner to reduce BRVC losses in a time of extreme             
          revenue shortages.  It is apparent that petitioner's efforts                
          began to pay off when, in 1993, BRVC again generated gross                  
          income.  Although BRVC expenses remained relatively low, losses             
          were nevertheless sustained during 1993 and 1994.  However, by              
          1998 BRVC began experiencing financial improvements as BRVC                 
          reported gross income of $13,188 and a net profit of $32.9  This            
          pattern of income and losses, coupled with petitioner's actions             
          in response thereto, indicates that petitioner possessed a profit           
          motive in operating BRVC.                                                   
               The seventh factor is the amount of occasional profits of              
          BRVC, if any.  The record reflects that BRVC realized a profit in           
          only 2 years of operation, $2,000 in 1986 and $32 in 1998.  A               
          minuscule loss of $29 was sustained in 1987.  Admittedly, viewed            
          in the most favorable light these profits were sporadic and                 
          small.  This fact does not weigh in favor of a profit motive.               
          Nevertheless, in this case the Court considers that the                     
          infrequency of net profits is not as significant as the pattern             
          of income and expenses.  The fact that profits were small and               
          occasional does not outweigh the fact that, when the receipts of            
               9    The Court is puzzled by the omission of return                    
          information for 1995 through 1997.  Nevertheless, given the                 
          income pattern in other years, the Court surmises that BRVC                 
          experienced a steady increase in gross income between the years             
          1994 and 1998.                                                              
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