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We are satisfied that petitioner’s gambling activity was
conducted with the requisite continuity and regularity during the
taxable year to allow for treatment as a trade or business within
the meaning of section 162(a). Nevertheless, in order for an
activity to be considered a trade or business within the meaning
of that section, a taxpayer’s primary purpose fo engaging in the
activity must be for income or profit. See Commissioner v.
Groetzinger, supra; Miller v. Commissioner, T.C. Memo. 1998-463,
affd. 208 F.3d 214 (6th Cir. 2000). Furthermore, as was the
situation in Groetzinger, the activity in question must be the
taxpayer’s “intended livelihood source”. Commissioner v.
Groetzinger, supra at 33.
The test of whether a taxpayer conducted an activity for
profit is whether he or she entered into, or continued, the
activity with an actual or honest objective of making a profit.
Keanini v. Commissioner, 94 T.C. 41, 46 (1990); Dreicer v.
Commissioner, 78 T.C. 642, 644-645 (1982), affd. without opinion
702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs.
Although a reasonable expectation of profit on a taxpayer’s part
is not required, the profit objective must be bona fide, as
determined from a consideration of the surrounding facts and
circumstances. Keanini v. Commissioner, supra; Dreicer v.
Commissioner, supra at 645; Golanty v. Commissioner, 72 T.C. 411,
425-426 (1979), affd. without published opinion 647 F.2d 170 (9th
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