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(10th Cir. 1956); Lewis v. Commissioner, T.C. Memo. 1992-420;
Stubblefield v. Commissioner, T.C. Memo. 1988-480.
There is no evidence in the record that petitioner has ever
earned a profit from his artist activity. In addition to the
losses reported during 1992 through 1995, the years in issue,
petitioner also reported losses for every year from 1984 through
1991. Petitioner’s two advertisements to solicit work as a
commissioned artist of portraits in 1992 cost him about $1,200
and resulted in only two commissioned portraits that generated
about $850 in revenue. Petitioner has demonstrated a change in
the type of artwork he creates, but he has not presented evidence
of a change in his operating methods that would allow him to
generate a profit from his artist activities. Petitioner has not
reversed his uninterrupted history of losses, and such losses
tend to indicate that he was content to sustain those losses for
purely personal reasons. See Breckenridge v. Commissioner, T.C.
Memo. 1983-66.
The amount of profits in relation to the amount of losses
incurred may provide useful criteria in determining the
taxpayer’s intent. See sec. 1.183-2(b)(7), Income Tax Regs.
Petitioner’s income from his artist activities consisted of
donations and commissions, and such income was insufficient to
offset any significant portion of the expenses resulting from
petitioner’s artist activity. See Golanty v. Commissioner, supra
at 431. The gross receipts from petitioner’s artist activity
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