William Herbert Whitehurst, III and Carla Cherlene Whitehurst - Page 8




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          the time and effort expended by the taxpayer in carrying on the             
          activity; (4) the expectation that assets used in the activity              
          may appreciate in value; (5) the success of the taxpayer in                 
          carrying on 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, if any, which are           
          earned; (8) the financial status of the taxpayer; and (9) the               
          elements of personal pleasure or recreation.  Sec. 1.183-2(b),              
          Income Tax Regs.                                                            
               We now consider whether Mrs. Whitehurst’s bowling activity             
          was an activity she pursued with the objective of making a                  
          profit.  Not all of the factors listed above are applicable to              
          the facts of this case; therefore, we focus on only those factors           
          that are relevant.                                                          
               a.  Manner in Which the Taxpayer Carries On the Activity               
               When considering the manner in which the taxpayer carried on           
          the activity, we may consider whether she carried on the activity           
          in a businesslike manner and maintained complete and accurate               
          books and records that indicate that she engaged in the bowling             
          activity for a profit.  Sec. 1.183-2(b)(1), Income Tax Regs.  A             
          change of operating methods, adoption of new techniques, or                 
          abandonment of unprofitable methods may indicate a profit motive.           
          Id.                                                                         








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