- 16 - 2004; (4) other expenses relating to the Dodge van of $1,800, $100, $170, and $155 claimed for petitioners’ respective taxable years 2001 through 2004; (5) bank service charges of $240, $240, and $262 for petitioners’ respective taxable years 2001 through 2003 and an unidentified amount of bank service charges for their taxable year 2004; (6) $183, $158,13 and $63 of the total premi- ums for their homeowner’s insurance policy for petitioners’ respective taxable years 2001 through 2003; and (7) delinquent New York state sales tax of $1,100 claimed for petitioners’ taxable year 2004. In order for a taxpayer to be carrying on a trade or busi- ness within the meaning of section 162(a), the taxpayer must be involved in the activity with continuity and regularity. Commis- sioner v. Groetzinger, 480 U.S. 23, 35 (1987). A sporadic activity will not qualify as carrying on a trade or business for purposes of section 162(a). Id. In addition, the taxpayer’s primary purpose for carrying on the activity must be for income or profit. Id. On the record before us, we find that petitioners have failed to carry their burden of establishing that during each of the years at issue Mr. Agbaniyaka was involved in his claimed arts and crafts business with continuity and regularity and that the primary purpose for the activities that he undertook with 13See supra note 12.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 10, 2007