- 30 - 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 dailyPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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