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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(1) and (2) 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 to section 212 are the same as those
used in 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. 686 (1988); Allen v. Commissioner, 72 T.C. 28, 33
(1979); Rand v. Commissioner, 34 T.C. 1146, 1149 (1960).
Whether the required profit objective exists is to be
determined on the basis of all the facts and circumstances of
each case. See Hirsch v. Commissioner, 315 F.2d 731, 737 (9th
Cir. 1963), affg. T.C. Memo. 1961-256; Golanty v. Commissioner,
72 T.C. 411, 426 (1979), affd. without published opinion 647 F.2d
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