Fred Misko, Jr. and Karen L. Howe-Misko - Page 10

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          enter into the leasing activity with the primary purpose to                 
          profit.                                                                     
               Petitioner argues that we should group the equipment leasing           
          activity with his law practice in determining whether there was a           
          profit motive.  Alternatively, petitioner argues that, if we do             
          not group the activities, he engaged in the leasing activity for            
          profit.  Respondent counters that the leasing activity and the              
          law practice cannot be grouped because they are separate                    
          activities, and that the leasing activity was not an activity               
          engaged in for profit.                                                      
               A.   Whether Petitioner’s Law Practice and His Leasing                 
                    Activity May Be Grouped for Purposes of Section 183               
               A taxpayer’s various activities may be viewed as a single              
          activity if they are sufficiently interconnected.  See sec.                 
          1.183-1(d)(1), Income Tax Regs.  We look to the organizational              
          and economic interrelationship of the activities, their business            
          purpose, and their overall similarity in determining whether they           
          may be viewed collectively.  Id.  Further, the Commissioner will            
          generally accept a taxpayer’s characterization of his or her                
          various undertakings as one activity unless it appears that the             
          characterization is artificial and unsupported by the facts.  Id.           
               Section 183 applies, however, only to individuals and S                
          corporations.  See sec. 1.183-1(a), Income Tax Regs. (extending             
          section 183 application to trusts and estates because they are              
          taxed as individuals).  Further, the section 183 regulations                





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