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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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