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was so involved, he was acting on behalf of Arbor. The record as
a whole indicates otherwise.
We agree that merely providing services to a corporation to
increase its value does not rise to the level of a trade or
business other than a trade or business of performing services as
an employee. However, while petitioner did devote substantial
time and effort to running the business of Arbor, his activities
were not so limited. Petitioner was actively involved in
procuring licenses for operation of nursing homes, selecting
location of buildings and their design, and similar engagements.
Moreover, the 1983 Development Agreement attests to the intention
of petitioner and Pomeroy to engage in a trade or business of
developing “various real estate and building projects, primarily,
although not exclusively, nursing homes and housing for the
elderly.” The record demonstrates that petitioner fulfilled that
intention during the years in question.
A trade or business is a continuous and regular vocation
engaged in for profit. See generally Commissioner v.
Groetzinger, 480 U.S. 23 (1987). According to the record, during
the years at issue, petitioner actively carried out the business
activities referenced in 1983 Development Agreement. We find
that these activities rose to the level of his own trade or
business pursuant to the terms of the 1983 Development Agreement.
See Hoffman v. Commissioner, supra. We hold that during 1995 and
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