Richard A. Stasewich - Page 9

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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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