Ruth N. Nelson - Page 30




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          incurring large expenditures in a hobby type business are much              
          greater for a taxpayer who has substantial income from other                
          sources.  See Jackson v. Commissioner, 59 T.C. 312, 317 (1972).             
               Finally, the Court must examine the degree of personal                 
          pleasure and recreation petitioner may have derived from the                
          conduct of BRVC.  Petitioner admittedly had a great love for the            
          sport of volleyball and experienced a certain level of personal             
          pleasure from conducting volleyball camps and clinics and                   
          sponsoring a membership program for tournament play, thereby                
          promoting the development of young volleyball athletes.  However,           
          the Court believes that the BRVC activities conducted by                    
          petitioner also proved, at times, to be demanding, exhausting,              
          and expensive, both physically and financially.  Nevertheless,              
          the mere fact that a taxpayer derives a certain amount of                   
          personal pleasure from an activity does not, in and of itself,              
          render the activity not engaged in for profit.  See sec. 1.183-             
          2(b)(9), Income Tax Regs.  Moreover, a business will not be                 
          recharacterized as a hobby merely because the owner finds the               
          activity pleasurable; i.e., suffering has never been made a                 
          prerequisite to deductibility.  See Jackson v. Commissioner,                
          supra.                                                                      
               The majority of people who engage in an activity for                   
          primarily pleasurable purposes, i.e., a hobby, choose an activity           
          that differs greatly from experiences provided in their daily               






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