Christopher Joseph Bush and Robin Leigh Pickering - Page 9

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          of business operations.  Petitioner maintained a separate                   
          checking account for Aspiring Artists, but Jennifer's mother,               
          petitioner Robin Leigh Pickering, made some VSA tuition payments            
          out of her personal checking account.  Commingling of funds                 
          indicates that an activity is more closely related to a hobby               
          than a business.  See Lundquist v. Commissioner, T.C. Memo. 1999-           
          83, affd. without published opinion 211 F.3d 600 (11th Cir.                 
          2000).  While petitioner claims to have advertised Aspiring                 
          Artists’ services during the year in issue, this Court finds that           
          there is no evidence of “advertising” until August of 1997.                 
          Petitioner’s “advertising” efforts consisted of soliciting                  
          students interested in commuting to VSA for a fee.  Had the                 
          solicitations been effective, the fees would merely have                    
          mitigated the cost of Jennifer’s auto expenses.                             
               Additionally, petitioner failed to create any type of                  
          business plan which outlined strategies ensuring a profitable               
          business venture.  Petitioner failed to create any type of budget           
          or break-even analysis.  Petitioner did not know when, or how, if           
          ever, he would make a profit, and there was no concerted or                 
          articulated effort to make that a reality.  Such lack of                    
          information upon which to make educated business decisions tends            
          to belie a taxpayer’s contentions that an activity was pursued              
          with the primary objective of making a profit.  Dodge v.                    
          Commissioner, T.C. Memo. 1998-89, affd. without published opinion           

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