-15- 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 andPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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