Horace D'Angelo - Page 15

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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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