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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 other
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