- 8 - has personal or recreational elements. Sec. 1.183-2(b)(8), Income Tax Regs. Petitioner contends that he engaged in the airplane activity for profit. We disagree. The evidence does not establish that petitioner carried on his airplane activity in a businesslike manner. Petitioner has consistently reported substantial net losses from his airplane activity and used the losses to offset significant wages that petitioner earned from American and taxable pensions and annuity income. The uninterrupted, substantial losses realized in petitioner’s airplane activity over many years are highly indicative of a lack of profit objective. See Golanty v. Commissioner, supra at 426. Petitioner testified that a business plan for his airplane activity was developed in 1996 (namely, to build from kits and to sell airplanes for a substantial profit). Petitioner, however, did not offer into evidence written documentation of this business plan. Petitioner acknowledged that prior to 1996 his airplane activity was “a pencil and paper operation”. Other than income tax returns, flight logs, and a business license (issued to petitioner during the last month of the last year at issue herein), petitioner did not offer into evidence any written documentation of his business plans or projections, payroll or other employee records, sales contracts, or any otherPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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