- 25 - Petitioner contends that a small chance of making a large profit may indicate the requisite profit objective. Sec. 1.183- 2(a), Income Tax Regs. Specifically, petitioner argues that the cash and prizes available per season totaled $1,250,000 and he believed he could earn a profit of $500,0004 per season. Petitioner does not specify how many or which tournaments he believed he could win to generate this profit. Petitioner has not persuaded us that he had a chance either to make a profit or to recoup his losses. The chance to make a large profit factor weighs against petitioner. Substantial income from sources other than the activity, particularly if the losses from the activity generate substantial tax benefits, may indicate that the activity is not engaged in for profit. Sec. 1.183-2(b)(8), Income Tax Regs. Although petitioner was employed by Kodak during the years in issue, his income was not substantial. The income from other sources factor is neutral. The presence of personal motives in the carrying on of an activity may indicate that the activity is not engaged in for profit, especially where there are recreational elements involved. Sec. 1.183-2(b)(9), Income Tax Regs. Petitioner argues that he suffers from severe motion sickness. Petitioner 4Petitioner states that this amount is in “today’s dollars” but does not provide any details regarding his sources of data or present value computations.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: November 10, 2007