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and effort in pursuit of this activity. This factor favors
petitioner.
A profit objective is strongly indicated where the taxpayer
has experienced a series of profitable years. Sec. 1.183-
2(b)(6), Income Tax Regs. Detailed financial information about
petitioner’s other taxable years is not available on this record.
An opportunity to earn a substantial ultimate profit in a highly
speculative venture is ordinarily sufficient to indicate that the
activity is engaged in for profit even though losses or only
occasional small profits are actually generated. Sec. 1.183-
2(b)(7), Income Tax Regs. Although it was modest in amount,
petitioner enjoyed a profit from gambling during the year in
issue. This factor is neutral or slightly favors petitioner.
The next factor significant in our inquiry is the financial
status of the taxpayer. A profit objective might be indicated
where the taxpayer does not have substantial income from sources
other than the activity. Sec. 1.183-2(b)(8), Income Tax Regs.
Petitioner held no substantial investments during 2001, and his
part-time employment as a delivery truck driver was his only
other source of income. Under the circumstances, the amount of
his wages gives little insight into his profit objective. On
balance, we consider this factor to be neutral.
A lack of profit objective might be indicated where there
are personal motives for carrying on the activity, especially
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