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as otherwise provided in section 183(b).2 An "activity not
engaged in for profit" means any activity other than one for
which deductions are allowable under section 162 or under
paragraph (1) or (2) of section 212. Sec. 183(c).
Deductions are allowed under section 162 for the ordinary
and necessary expenses of carrying on an activity that
constitutes the taxpayer's trade or business. Deductions are
allowed under section 212 for expenses paid or incurred in
connection with an activity engaged in for the production or
collection of income, or for the management, conservation, or
maintenance of property held for the production of income. With
respect to either section, however, the taxpayer must demonstrate
a profit objective for the activity in order to deduct associated
expenses. See Jasionowski v. Commissioner, 66 T.C. 312, 320-322
(1976); sec. 1.183-2(a), Income Tax Regs. The profit standards
applicable for section 212 are the same as those used for section
162. See Agro Science Co. v. Commissioner, 934 F.2d 573, 576
(5th Cir. 1991), affg. T.C. Memo. 1989-687; Antonides v.
Commissioner, 893 F.2d 656, 659 (4th Cir. 1990), affg. 91 T.C.
2Sec. 183(b)(1) permits a deduction for expenses that are
otherwise deductible without regard to whether the activity is
engaged in for profit, such as personal property taxes. Sec.
183(b)(2) permits a deduction for expenses that would be
deductible only if the activity were engaged in for profit, but
only to the extent that the gross income derived from the
activity exceeds the deductions allowed by sec. 183(b)(1).
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