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BRVC began to decrease, a commensurate decrease in expenses was
accomplished in attempt to remedy the situation. Additionally,
petitioner carried out recurrent conversions in the activities of
BRVC in an ongoing effort to make the business profitable. The
fact that petitioner's efforts proved to be somewhat fruitless
does not require a finding of no profit motive.
The eighth factor is petitioner's financial status. From
1981 through 1985, petitioner was paid wage income by LSU,
although the amounts of such wage income are not a part of this
record. During 1986, 1988, and 1998, petitioner's only income
was derived from BRVC with the exception of $2,782 in interest
income in 1986, $3,339 in interest income in 1988, and $3,103 in
interest and dividend income in 1998.10 For 1987, petitioner had
wage income of $12,250 and interest income of $3,498. For 1989,
petitioner reported wages of $17,808, interest income of $4,173,
a $2,509 gain from the sale of an automobile, and $880 in
unemployment compensation.11 For 1990, petitioner reported wages
10 In addition to her loss from BRVC for 1988, petitioner
claimed a capital loss of $153. For 1998, petitioner also
reported a capital loss of $719 and a net operating loss
carryover of $6,203.
11 For 1989, petitioner also reported, in addition to the
BRVC loss, a $3,000 capital loss, a loss of $8,945 from the
operation of rental real estate, and a net operating loss
carryover of $12,055.
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