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objective, where the issue was raised by the Commissioner as a
new matter). We start by noting that petitioner’s leasing
activity was not a hobby masquerading as a business. See
Cornfeld v. Commissioner, 797 F.2d 1049, 1052 (D.C. Cir. 1986),
revg. T.C. Memo. 1984-105. This distinguishes a large class of
cases where profit objective is reasonably placed in doubt
because the taxpayer derives an intangible personal benefit from
the purported business. Id.; see Bessenyey v. Commissioner, 379
F.2d 252 (2d Cir. 1967) (raising Hungarian half-breds held not to
be an activity for profit), affg. 45 T.C. 261 (1965); sec. 1.183-
2(a), Income Tax Regs. Further, nothing in the record suggests
that petitioner’s equipment was purchased for personal use. See,
e.g., Westerman v. Commissioner, 55 T.C. 478 (1970); Fischer v.
Commissioner, 50 T.C. 164, 171 (1968).
The record establishes without contradiction that petitioner
was an astute businessman and attorney. He earned substantial
income from the law firm, and he accomplished this in part
through his expertise in operating the leased equipment, which
was crucial to his legal practice. Further, petitioner engaged
in the leasing activity on the advice of his accountant, he used
the equipment solely for the law firm, he collected rent
consistently except during the years at issue, he had a high
degree of knowledge and skill related to the equipment, he kept
records regarding amounts invested, rents received, and
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