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explicitly except C corporations, stating that no inference may
be drawn from section 183 and its regulations as to whether a
corporation is engaged in an activity for profit. Sec. 1.183-
1(a), Income Tax Regs. The point of amalgamating two
undertakings into a single activity is to net the expenses of one
against the revenue of the other, an objective that cannot be
accomplished where one undertaking is that of a C corporation and
the other is an undertaking by an individual. Because the law
firm was a C corporation, petitioner may not group the law firm
with his leasing activity for purposes of section 183.8
B. Whether the Activity Was Engaged In for Profit
Although we agree with respondent that the leasing activity
and the law practice cannot be grouped, we nonetheless find that
respondent has failed to meet his burden to show that petitioner
did not engage in the leasing activity with the primary purpose
to earn a profit. See Swaffar v. Commissioner, T.C. Memo. 1992-
180 (the Court did not affirmatively find that the taxpayers
lacked a profit objective, but rather found only that the
Commissioner failed to prove that the taxpayers lacked a profit
8Petitioner also argues that, if we do not group the two
undertakings, the law firm’s profit objective still should be
attributed to his leasing activity. See Campbell v.
Commissioner, 868 F.2d 833 (6th Cir. 1989), revg. T.C. Memo.
1986-569; Wilkinson v. Commissioner, T.C. Memo. 1996-39; De
Mendoza v. Commissioner, T.C. Memo. 1994-314; Kuhn v.
Commissioner, T.C. Memo. 1992-460; cf. Baldwin v. Commissioner,
T.C. Memo. 2002-162. We need not resolve this issue.
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