- 11 - realization of a profit. We find that these factors favor respondent. 8. Financial Status of the Taxpayer A profit objective may be indicated where the taxpayer does not have substantial income from sources other than the activity. Sec. 1.183-2(b)(8), Income Tax Regs. Petitioners’ separate wage and salary income provided a substantial source of income apart from the distributorship: Petitioners’ taxable income from their employment for 1996 and 1997 was in the amount of $67,000 and $72,403, respectively. We find that this factor favors respondent. 9. Elements of Personal Pleasure or Recreation A lack of profit objective may be indicated where there are personal motives for carrying on the activity, especially where the motive is personal pleasure or recreation. Sec. 1.183- 2(b)(9), Income Tax Regs. Profit need not be the only objective, however, and personal motives may coexist with an actual and honest intent to derive a profit. Id. The significance of personal motives in this case is difficult to gauge. On the one hand, petitioners expended a substantial amount of time in activities, such as driving long distances, which would appear to lack elements of pleasure or recreation. On the other hand, much of petitioners’ activities involved elements which were very personal in nature, such asPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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