Ruth N. Nelson - Page 29




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          of $40,207 and interest income of $3,784.12  For 1991, petitioner           
          reported wages of $57,344 and interest income of $4,139.13                  
               During the years at issue, petitioner was employed by SOI              
          and earned wages of $54,118 and $38,029 for 1992 and 1993,                  
          respectively.  Additionally, for 1992, petitioner reported                  
          interest income of $2,757, a State income tax refund of $245, a             
          $3,000 capital loss, and a $1,940 loss from the operation of                
          rental real estate.  For 1993, petitioner reported interest                 
          income of $2,225, a State income tax refund of $729, a $3,000               
          capital loss, and a loss of $1,817 from the operation of rental             
          real estate.                                                                
               For each of the years of operation, the amounts of income              
          derived by petitioner outside of BRVC are not so high as to                 
          indicate that petitioner's primary objective in operating BRVC              
          was to generate tax savings, particularly in light of the other             
          losses reported on petitioner's returns for various years.  On              
          the contrary, these levels of other income and losses indicate              
          that petitioner lacked the luxury of a large amount of disposable           
          income that would enable her to fritter away tens of thousands of           
          dollars each year on a volleyball hobby.  The tax incentive for             

               12   In addition to the BRVC loss for 1990, petitioner                 
          reported a $3,000 capital loss, a $3,057 loss from the operation            
          of rental real estate, and a net operating loss carryover of                
          $36,517.                                                                    
               13   Additionally, petitioner reported a $3,000 capital                
          loss, a $5,512 loss from the operation of rental real estate, and           
          a $24,388 net operating loss carryover.                                     




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