Randall B. and Kay F. Ollett - Page 11

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          limitations of section 183, the taxpayer must show that he                  
          engaged in the activity with an actual and honest objective of              
          making a profit.  Keanini v. Commissioner, 94 T.C. 41, 46 (1990);           
          Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without             
          opinion 702 F.2d 1205 (D.C. Cir. 1983); Lopez v. Commissioner,              
          T.C. Memo. 2003-142.  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.  Keanini v.                  
          Commissioner, supra at 46; Lopez 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.                   
          Keanini v. Commissioner, supra at 46; 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, supra at 46; Lopez v. Commissioner, supra.                    
               Regulations promulgated under section 183 provide the                  
          following nonexclusive list of factors which normally should be             
          considered in determining whether an activity was engaged in for            
          profit:  (1) The manner in which the taxpayer carried on the                
          activity; (2) the expertise of the taxpayer or his advisers; (3)            






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