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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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