- 13 - also for all other disallowed expenses related to her interior design and equestrian activities. OPINION Section 183 restricts taxpayers from deducting losses from an activity that is not “engaged in for profit”. Sec. 183(a). An activity is engaged in for profit if the taxpayer entertained an actual and honest profit objective in engaging in the activity. Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs. The taxpayer’s expectation of profit must be in good faith. Allen v. Commissioner, 72 T.C. 28, 33 (1979) (citing sec. 1.183-2(a), Income Tax Regs.). I. Burden of Proof Petitioner argues that under section 7491(a), the burden of proof has shifted to respondent. Conversely, respondent contends the burden has not shifted because petitioner was not cooperative within the meaning of section 7491(a), and because petitioner failed to introduce credible evidence necessary for the burden to shift. It is unnecessary for us to address the parties’ disagreements and to determine whether the burden of proof has shifted because the outcome of this case is determined on the preponderance of the evidence after trial and is unaffected by section 7491. Estate of Bongard v. Commissioner, 124 T.C. 95 (2005) (citing Blodgett v. Commissioner, 394 F.3d 1030, 1035 (8thPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: November 10, 2007