-16-
sec. 165(d). Petitioner thus had no tax incentive to engage in
the gambling activity to shield income from other endeavors. We
conclude that this factor is neutral.
Whether Elements of Personal Pleasure or Recreation Are Involved
We next examine whether elements of personal pleasure or
recreation were involved in the gambling activity. The presence
of recreational or pleasurable motives in conducting an activity
may indicate that the taxpayer is not conducting the activity for
profit. Sec. 1.183-2(b)(9), Income Tax Regs.; see Calvao v.
Commissioner, T.C. Memo. 2007-57 (taxpayer’s gambling strategy
and desire to win found consistent with gambling for
entertainment or recreational purposes). That the taxpayer
derives personal pleasure from engaging in the activity is
insufficient to cause the activity to be classified as not
engaged in for profit if other factors show that the activity is
conducted for profit. Jackson v. Commissioner, supra; sec.
1.183-2(b)(9), Income Tax Regs.
We acknowledge that gambling at a casino is an activity
commonly understood to be a pleasant amusement. Petitioner
testified credibly, however, that she found no pleasure in
gambling. It was work. Petitioner testified that she found
gambling to be stressful, tiring, and time consuming. She
further testified that she always went to the casino alone and
that no friends or family members accompanied her to add any
entertainment element to her activities. We find her testimony
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