-32-
considerable net income during each of the relevant years. In
1993 alone, petitioners reported $5.5 million in wages. While
this factor is not helpful to petitioners’ contention, it does
not foreclose a profit motive. See id.
9. Whether Elements of Personal Pleasure or Recreation Are
Involved
We next examine whether elements of personal pleasure or
recreation were involved in the activity. The presence of
recreational or pleasurable motives in conducting an activity may
indicate that the taxpayer is not conducting the activity for
profit. Sec. 1.183-2(b)(9), Income Tax Regs. The fact that the
taxpayer derives personal pleasure from engaging in the activity
is not sufficient to cause the activity to be classified as not
engaged in for profit, however, if the activity is, in fact,
conducted for profit as shown by other factors. Jackson v.
Commissioner, supra; sec. 1.183-2(b)(9), Income Tax Regs.
Petitioners did make some personal trips in the Falcon.
Petitioners and respondent do not agree on the number and value
of the trips petitioners took for personal travel versus business
travel. The disagreement results in part from different views of
particular trips. For example, respondent characterized certain
trips from San Diego to Los Angeles made by Jennifer Heft
(petitioners’ daughter and a merchandising employee of CFI) to
meet with Ms. Little as personal trips, while petitioners
characterized Ms. Heft’s travel as business trips. Similarly,
respondent contended that petitioners’ trips to Aspen, Colorado,
were of a personal nature because Mr. Rabinowitz skied and
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