- 18 - illustrates that his personal goal was not a realistic one. We conclude that had he sought out advice on whether he could realistically start and parlay a profitable youth basketball school in Chicago into a lucrative job offer for himself, he would not have endeavored to make RBS a business.3 In sum, our conclusion with respect to this factor weighs in favor of respondent. Time and Effort Petitioner Expended in Carrying On the Activity The fact that the taxpayer devotes much of his personal time and effort to carrying on an activity may indicate an intention to derive a profit, particularly if the activity does not have substantial personal or recreational aspects. Golanty v. Commissioner, 72 T.C. at 426; sec. 1.183-2(b)(3), Income Tax Regs. Petitioner testified that he spent approximately 2 hours conducting weekly practice from May through July of each of the years in issue, and approximately 5 hours each of those weeks on administrative tasks related to RBS. In addition, petitioner would spend upwards of 12 hours a day on the days that the RBS team would participate in tournaments. Petitioner testified that he took pleasure in watching his players and in the reputation he was building as a youth 3 We note that, in 2004, petitioner applied for, and received, sec. 501(c)(3) status to operate RBS as a charitable entity.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: November 10, 2007