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petitioners have at no time throughout this proceeding raised an
argument that the Shrike Cars operations should be considered as
a component of one of their other entities or ventures.
Furthermore, taxpayers in general must live with the manner in
which they have structured and delineated their business entities
and transactions. See Commissioner v. Natl. Alfalfa Dehydrating
& Milling Co., 417 U.S. 134, 149 (1974) (“This Court has observed
repeatedly that, while a taxpayer is free to organize his affairs
as he chooses, nevertheless, once having done so, he must accept
the tax consequences of his choice, whether contemplated or not,
* * * and may not enjoy the benefit of some other route he might
have chosen to follow but did not.”) Accordingly, our inquiry is
whether Shrike Cars, viewed as a stand-alone concern, had
achieved the status of an active trade or business in 1998.
As alluded to previously, the principal inference to be
drawn from the record seems to be that the alleged Shrike Cars
business rested somewhere on a continuum from vehicle production
to marketing and that petitioners engaged in a variety of other
activities at the marketing end. Yet the above authorities
direct our attention to whether Shrike Cars had begun to function
as a going concern in performing the activities for which it was
organized. The intended discrete business of Shrike Cars is
therefore a pertinent fact. However, because we conclude that
the record fails to show that Shrike Cars had begun in 1998 to
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