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participation in a research study, an experience which he
believed would in turn help him in conducting his own research.
In short, we find that petitioner had a de minimis amount of
income in both of the activities during the years in issue. We
find that petitioner’s claimed expenditures in these activities
over the course of 4 years, totaling over $100,000, objectively
indicates that petitioner did not expect a profit or engage in
the activities with an intent to profit. These factors strongly
favor respondent.
Financial Status of the Taxpayer
A profit objective may be indicated where the taxpayer does
not have substantial income from sources other than the activity.
Sec. 1.183-2(b)(8), Income Tax Regs. During the years in issue,
petitioner was employed on a part-time basis at a halfway house
for psychiatric patients. Petitioner wife was employed by a
school district. Petitioners received combined wage income,
interest income, and dividends totaling $35,834, $40,979,
$48,001, and $47,970 in 1996, 1997, 1998, and 1999, respectively.
Thus, petitioners had modest but reliable sources of income
during the years in issue. This factor favors respondent.
Elements of Personal Pleasure or Recreation
A lack of profit objective may be indicated where there are
personal motives for carrying on the activity, especially where
the motive is personal pleasure or recreation. Sec. 1.183-
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