- 16 -
objective. See id.
None of the above factors supports petitioners’ claim of an
economic profit objective independent of tax savings. See
Surloff v. Commissioner, 81 T.C. at 233. We therefore conclude
that petitioners did not enter into the RTP activity with a
profit objective. Given our conclusion, we need not decide
whether petitioners substantiated their claimed Schedule C
deductions.9 We also need not address section 183(b)(2) because
respondent allowed expenses related to the activity to the extent
of the activity’s gross income. See sec. 183(a) and (b)(2).
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
9 Under sec. 213(a), medical expenses paid and not
compensated for by insurance are deductible to the extent they
exceed 7.5 percent of adjusted gross income (AGI). Even if
petitioners could substantiate their claimed medical expenses,
such expenses would not exceed the AGI threshold.
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