- 5 - As a result of an audit examination, on May 6, 1998, respondent issued a notice of deficiency to petitioners in which respondent determined that, for 1994, 1995, and 1996, petitioner’s airplane activity was not engaged in for profit under section 183, and respondent disallowed the claimed losses for each of those years. Also, respondent determined accuracy- related penalties under section 6662. Respondent has conceded that the claimed expenses relating to petitioner’s airplane activity have been substantiated for the years at issue and that during the years 1986 through 2001 petitioner spent approximately $1 million of his own funds on his airplane activity. During a prior audit of petitioners’ 1989, 1990, and 1991 Federal income tax returns, respondent did not raise an issue as to petitioner’s profit objective relating to petitioner’s airplane activity. OPINION Activity not Engaged in for Profit Generally, under section 183, if an activity is not engaged in for profit, deductions for expenses relating to such activity are allowable only to the extent of gross income derived from the activity.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011