Diane S. Blodgett - Page 16

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          233 (1983).  Greater weight is given to objective facts than to             
          the parties’ mere statements of intent.  Engdahl v. Commissioner,           
          72 T.C. 659, 666 (1979).  In determining whether an activity was            
          entered into for profit, the following factors are considered:              
          (1) The manner in which the taxpayers carried on the activity;              
          (2) the expertise of the taxpayers or their advisers; (3) the               
          time and effort expended by the taxpayers in carrying on the                
          activity; (4) an expectation that the assets used might                     
          appreciate in value; (5) the success of the taxpayer in carrying            
          other similar or dissimilar activities; (6) the taxpayer’s                  
          history of income or losses with respect to the activity; (7) the           
          amount of occasional profits earned; (8) the financial status of            
          the taxpayer; and (9) the existence of elements of personal                 
          pleasure in carrying out the activity.  Sec. 1.183-2(b), Income             
          Tax Regs.                                                                   
               On this record, the Court concludes that the purchase of the           
          condominium and lot was not engaged in for profit, either from              
          business or investment.  The Court reaches this conclusion based            
          on petitioner and Mr. Blodgett’s lack of expertise in the real              
          estate business, their insufficient time and effort expended in             
          carrying out any rental of the condominium, a lack of market                
          analysis on the appreciation potential of the property, and the             
          lack of credibility of the witnesses at trial.  Although                    
          petitioner claimed she and Mr. Blodgett purchased the Florida               





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