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sources, losses over a number of years, and tax benefits are
features characteristic of an activity not operated for profit).
Accordingly, we find that petitioners failed to meet their burden
to establish that Mr. Lofstrom engaged in his writing activities
with a bona fide profit objective.
Conclusion
We sustain respondent’s determinations in the deficiency
notice for 1997 and 1998. In reaching our holding, we have
considered all arguments made, and, to the extent not mentioned,
we conclude that they are moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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