- 9 - (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 activityPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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