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ranged from $266 to $770 annually, during the years in issue,
while expenses ranged from $11,279 to $32,544 annually. Based on
the evidence, it appears that petitioner never expected to recoup
the large losses that he generated from his artist activity.
Substantial income from sources other than the activity may
indicate that the activity is not engaged in for profit. See
sec. 1.183-2(b)(8), Income Tax Regs. In general, a taxpayer with
substantial income unrelated to the activity can more readily
afford a hobby. See Stasewich v. Commissioner, supra.
Petitioner had an independent source of income, from his
accounting business, and did not rely on his artist activity to
support himself. Additionally, for 1991 and 1993 (although 1991
is not in issue) petitioner reported a loss from his artist
activity exactly equal to the income from his accounting
activity. Such an unlikely coincidence indicates that petitioner
may be using his artist activity as a device to eliminate Federal
income tax on the income from his accounting business. This
pattern weighs against finding a profit objective.
That a taxpayer derives personal pleasure from a particular
activity does not necessarily mean that he or she lacks a profit
objective with respect to the activity. See Glenn v.
Commissioner, T.C. Memo. 1995-399, affd. without published
opinion 103 F.3d 129 (6th Cir. 1996); sec. 1.183-2(b)(9), Income
Tax Regs. Where, however, there are recreational or other
personal elements involved, the personal motives may negate the
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