N. Thomas Ryan - Page 9

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          profit:  (1) The manner in which the taxpayer carried on the                
          activity; (2) the expertise of the taxpayer or his advisers; (3)            
          the time and effort expended by the taxpayer in carrying on the             
          activity; (4) the expectation that the assets used in the                   
          activity may appreciate in value; (5) the success of the taxpayer           
          in carrying on other similar or dissimilar activities; (6) the              
          taxpayer’s history of income or losses with respect to the                  
          activity; (7) the amount of occasional profits, if any, which are           
          earned; (8) the financial status of the taxpayer; and (9)                   
          elements of personal pleasure or recreation.  Sec. 1.183-2(b),              
          Income Tax Regs.  No single factor, nor the existence of even a             
          majority of the factors, is controlling, but rather it is an                
          evaluation of all the facts and circumstances in the case, taken            
          as a whole, that is determinative.  Golanty v. Commissioner, 72             
          T.C. 411, 426-427 (1979), affd. without published opinion 647               
          F.2d 170 (9th Cir. 1981); sec. 1.183-2(b), Income Tax Regs.                 
                    1.  The Manner in Which the Taxpayer Carried On the               
                    Activity                                                          
               The fact that a taxpayer carries on the activity in a                  
          businesslike manner and maintains complete and accurate books and           
          records may indicate a profit objective.  Sec. 1.183-2(b)(1),               
          Income Tax Regs.                                                            
               Petitioner did not keep adequate and accurate records of his           
          horse breeding activity.  He did not describe measures he took              
          for bookkeeping or discuss a method for recording information               





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