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are not allowable for activities a taxpayer engaged in as a sport
or hobby or for recreation. Sec. 1.183-2(a), Income Tax Regs.
For a taxpayer’s expenses in an activity to be deductible
under section 162 or section 212, and not subject to the
limitations of section 183, the taxpayer must show that he
engaged in the activity with an actual and honest objective of
making a profit. Hulter v. Commissioner, 91 T.C. 371, 392
(1988); Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd.
without opinion 702 F.2d 1205 (D.C. Cir. 1983); Hastings v.
Commissioner, T.C. Memo. 2002-310. Although a reasonable
expectation of a profit is not required, the taxpayer’s profit
objective must be “actual and honest”. Dreicer v. Commissioner,
supra at 645; sec. 1.183-2(a), Income Tax Regs. Whether a
taxpayer has an actual and honest profit objective is a question
of fact to be resolved from all the relevant facts and
circumstances. Hulter v. Commissioner, supra at 393; Hastings v.
Commissioner, supra; sec. 1.183-2(a), Income Tax Regs. Greater
weight is given to objective facts than to a taxpayer’s statement
of intent. Dreicer v. Commissioner, supra at 645; sec. 1.183-
2(a), Income Tax Regs. As stated earlier, the taxpayer bears the
burden of establishing the requisite profit objective. Rule
142(a); Keanini v. Commissioner, 94 T.C. 41, 46 (1990); Hastings
v. Commissioner, supra.
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