- 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.Page: 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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