- 13 -
activity is not sufficient to cause the activity to be classified
as not engaged in for profit. Id.
Mrs. Whitehurst has been an avid bowler nearly all of her
life. During the years at issue and at the time of trial she was
a member of a bowling league, and she bowled with her family.
Mrs. Whitehurst testified that the bowling tournaments were long,
tiring, and difficult, but not pleasurable, and that driving to
tournaments in Florida was especially difficult. Although we
recognize that driving long hours to a bowling tournament is an
arduous task, we are not convinced that Mrs. Whitehurst does not
derive personal pleasure from or recreation in bowling. The
personal pleasure or recreation that she derives from the bowling
activity, however, is not sufficient to cause the bowling
activity to be classified as not engaged in for profit. See id.
Therefore, this factor is neutral.
Having considered the above factors and recognizing that no
one factor is controlling, we conclude that Mrs. Whitehurst
entered into the bowling activity with a profit objective and
thus hold for petitioners on this issue. See Engdahl v.
Commissioner, 72 T.C. 659, 671 (1979).
Issue 2. Expense Deductions
We now consider respondent’s alternative position that
petitioners are not entitled to certain claimed Schedule C
expenses related to the bowling activity. We will consider the
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011