- 52 - 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 ofPage: Previous 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 Next
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