-7- loss of $20,348 in 1999, gross receipts of $225 and a net loss of $22,197 in 2000, and gross receipts of $25 and a net loss of $18,826 in 2001. Petitioners deducted expenses relating to the drag racing activity on their tax returns for the years at issue. Respondent disallowed the deduction of petitioner’s losses in a notice of deficiency dated February 5, 2004, determining that petitioner did not engage in the drag racing activity for profit under section 183. Petitioners timely filed a petition with this Court seeking redetermination of the disallowed deductions and asserting that petitioner entered the drag racing activity with the intent of making a profit, and that, when he was not able to make a profit as anticipated, he liquidated the activity. Discussion A. Whether Petitioner Operated the Drag Racing Activity for Profit During the Years at Issue The sole issue for decision is whether petitioner operated the drag racing activity for profit during the years at issue within the meaning of section 183. Section 183(a) provides generally that if an individual engages in an activity and “if such activity is not engaged in for profit, no deduction attributable to such activity shall be allowed under this chapter except as provided in this section.” Deductions that would be allowable without regard to whether the activity is engaged in for profit shall be allowed under section 183(b)(1), and deductions that would be allowable only if the activity isPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011