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During this period, petitioner spent most of his time and effort
on his mining activities and relatively little time maintaining
his medical practice.
OPINION
I. Section 183(a) Deductions
A. In General
Section 183(a) provides that if an activity is not engaged
in for profit, no deduction attributable to the activity shall be
allowed except as provided in section 183(b). Section 183(b)(1)
allows those deductions that otherwise are allowable regardless
of profit objective. Section 183(b)(2) allows those deductions
that would be allowable if the activity was engaged in for
profit, but only to the extent that gross income attributable to
the activity exceeds the deductions permitted by section
183(b)(1). Section 183(c) defines “activity not engaged in for
profit” as “any activity other than one with respect to which
deductions are allowable for the taxable year under section 162
or under paragraph (1) or (2) of section 212.”
Deductions are allowable under section 162 for the expenses
of carrying on an activity that constitutes a trade or business
of the taxpayer. See sec. 162(a); sec. 1.183-2(a), Income Tax
Regs. To be engaged in a trade or business with respect to which
deductions are allowable under section 162, “the taxpayer must be
involved in the activity with continuity and regularity,” and
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