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revg. in part T.C. Memo. 1986-569, for the proposition that the
“entire economic relationship” of related companies must be
analyzed when making a determination regarding profit motivation.
Petitioner also relies upon several cases holding that the
taxpayer had a bona fide profit motive in what he contends are
similar situations. See, e.g., Cornfeld v. Commissioner, 797
F.2d 1049 (D.C. Cir. 1986); Horner v. Commissioner, 35 T.C. 231
(1960); Kuhn v. Commissioner, T.C. Memo. 1992-460; Lee v.
Commissioner, T.C. Memo. 1986-294; Louismet v. Commissioner, T.C.
Memo. 1982-294.
The cases cited by petitioner are readily distinguishable
because none of the cases involved an alleged business activity
conducted primarily for the personal benefit of the owner. For
example, in Campbell v. Commissioner, supra, the Court of Appeals
for the Sixth Circuit held that a taxpayer could deduct losses
from a partnership where the partnership’s only business purpose
was to lease an airplane to a corporation controlled by the
partners of the partnership. The corporation’s employees and
officers engaged in extensive air travel in furtherance of the
corporation’s business and used the partnership’s airplane to
facilitate that travel. Despite repeated losses in the
partnership, the Court of Appeals found a profit motive by
considering the overall increase in wealth of the partners
through the corporation, accomplished through the use of
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