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statement of intent. Thomas v. Commissioner, 84 T.C. 1244, 1269
(1985), affd. 792 F.2d 1256 (4th Cir. 1986).
Respondent determined that petitioner did not engage in his
basketball team activity (RBS) with an “actual and honest profit
objective”, and therefore disallowed the Schedule C business
expenses for the years at issue. Dreicer v. Commissioner, supra
at 645. Petitioner contends that he engaged in RBS with a profit
objective and therefore, is entitled to deduct from his gross
income the reported business expenses resulting in losses
relating to that activity. We now address the nine factors
provided in section 1.183-2(b), Income Tax Regs., in making our
determination.
Manner in Which Petitioner Carried On RBS
To determine whether a taxpayer carried on an activity in a
business like manner, the following may be considered: (1)
Whether the taxpayer maintained complete and accurate books and
records; (2) whether taxpayer’s conduct is substantially similar
to that of other profitable activities; and (3) whether taxpayer
made changes to improve the activity’s profitability. Sec.
1.183-2(b)1), Income Tax Regs.
Petitioner introduced little evidence showing that he kept
track of his expenses during the year. The record in this case
is devoid of any evidence that petitioner used monthly or yearly
business statements to gauge his profitability or to make
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