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profit objective. See sec. 1.183-2(b)(9), Income Tax Regs. We
previously stated, with respect to this factor:
Unquestionably, an enterprise is no less a “business”
because the entrepreneur gets satisfaction from his
work; * * * however, where the possibility for profit
is small (given all the other factors) and the
possibility for gratification is substantial, it is
clear that the latter possibility constitutes the
primary motivation for the activity. * * * [Burger v.
Commissioner, T.C. Memo. 1985-523, affd. 809 F.2d 355
(7th Cir. 1987); fn. ref. omitted.]
Based on the evidence, we conclude that petitioner did not
have a profit objective when he created his installation art
exhibits in the front of his residence. Petitioner received only
nominal donations that totaled $88.04 from his installation art
exhibits, and such donations could not have compensated him for
the time or expense involved in creating his artwork. Petitioner
did not seek to make a profit from his installation art exhibits,
but rather engaged in the artist activity because of the
satisfaction, pride, and prestige that it afforded him.
In the previous case of Stasewich v. Commissioner, supra, we
held that petitioner’s artist activity was not entered into for
profit for 1988 through 1991. Petitioner has not made any
significant changes in the operation of his artist activity,
during the years in issue here, that would create a market or
allow him to benefit from a market for his artwork or allow him
to make up for his substantial losses. In Stasewich v.
Commissioner, supra, we explained our holding in language equally
applicable here:
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