- 29 -
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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