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basketball coach. Petitioner was clear that although he wanted
to expose his players to talent scouts, his personal goal was to
establish and enhance his reputation as a talent scout himself so
that he would receive a job offer from an athletic shoe or
apparel company. We are convinced that petitioner spent a
considerable amount of his personal time on RBS from May through
July in each of the years in issue. Nevertheless, because RBS
was formed and operated--in great part--for petitioner’s personal
objectives, we conclude this factor in favor of respondent’s
position.
Expectation That Assets Used in Activity May Appreciate
The expectation that assets used in the activity will
appreciate in value sufficiently to lead to an overall profit
when netted against losses may indicate a profit objective.
Engdahl v. Commissioner, supra at 668-669. Neither petitioner
nor respondent argues that there are any assets involved with
RBS, including the value of its reputation, which is significant
enough to offset petitioner’s losses. Therefore, we view this
factor as neutral to our conclusion.
Success of Petitioner in Carrying On Similar Activities
The fact that the taxpayer had engaged in similar activities
in the past and converted them to profitable enterprises may
indicate that he engaged in the present activity for profit.
Lundquist v. Commissioner, T.C. Memo. 1999-83, affd. without
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