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winnings offered were significant. While Mrs. Whitehurst did not
earn a profit with respect to the activity, opportunity for
profit existed. These facts support the claim that she entered
into the bowling activity with a profit objective.
f. Financial Status of the Taxpayer
The fact that the taxpayer does not have substantial income
from sources other than the activity may indicate that the
activity is engaged in for profit. Sec. 1.183-2(b)(8), Income
Tax Regs. Substantial income from other sources may indicate
that the activity is not engaged in for profit especially if
there are personal or recreational elements in the activity. Id.
Petitioners’ combined wages totaled $81,104 in 1997, $87,667
in 1998, and $89,764 in 1999. Although Mrs. Whitehurst explained
that she and her husband did not earn as much income as they
wanted, their combined wage income for each of the 3 years at
issue is not insignificant. Given that personal and recreational
elements are involved in the bowling activity, as we discuss
below, this factor does not support an intent to profit. See id.
g. Elements of Personal Pleasure
The presence of personal motives in carrying on an activity
may indicate that the activity is not engaged in for profit,
especially where there are recreational or personal elements
involved. Sec. 1.183-2(b)(9), Income Tax Regs. The fact that
the taxpayer derives personal pleasure from engaging in the
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