- 37 - year from his bond trading activities and who offset his earned income with over $3,300,000 of LFI’s losses; (3) petitioner insured Granot Loma as a second residence and certain personal property at Granot Loma as his personal, and insurable, property; (4) LFI did not generate a profit from its alleged operation of Granot Loma during any year at issue; (5) petitioners never transferred Granot Loma’s legal title to LFI; and (6) petitioner and his family, friends, and business acquaintances derived considerable personal pleasure from their use of Granot Loma. On balance, we conclude that petitioner has failed to prove by a preponderance of evidence that LFI was engaged in the conduct of a trade or business under section 162 or that any activity allegedly conducted by LFI at Granot Loma was an activity for profit.17 Consequently, we sustain respondent’s determination that LFI was not engaged in an activity for profit. B. Respondent’s Determinations With Respect to LFI for 1989 and 1990 Section 183 disallows all expenses attributable to an activity not engaged in for profit except as provided in section 183(b). Section 183(b)(1) allows those deductions which are not 17Even if we were to reach petitioner’s section 212 argument, we would still conclude on this record that LFI was not engaged in an activity for profit.Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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