-18- anticipated a profit of $13,040 for 1999. Petitioner also decided to liquidate in 2000 and therefore minimized costs and entered fewer races. Petitioner has shown that he could earn enough money in a year to cover his expenses; he accomplished that in 1998. 8. The Financial Status of the Taxpayer We next examine petitioner’s financial status. If a taxpayer does not have substantial income or capital from sources other than the activity in question, it may indicate that the taxpayer engages in the activity for profit. Sec. 1.183-2(b)(8), Income Tax Regs. Conversely, substantial income from sources other than the activity, especially if the losses generate large tax benefits, may indicate that the taxpayer is not conducting the activity for profit. Id. Those with substantial income from other sources have a much greater tax incentive to incur large expenditures in a hobby type of business. Jackson v. Commissioner, 59 T.C. 312, 317 (1972). During the years at issue, petitioners’ financial status was stable. Petitioner earned a good salary from the bank but not in six figures. Both petitioners used some of their income from their full-time jobs at the bank to help support the drag racing activity during the startup phase. While petitioners’ financial status was stable, their income was not so substantial that it would indicate a great tax incentive to incur large losses from the drag racing activity.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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