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at least 1985, petitioner received no income and had no success
from his endeavors in or prior to the year in issue. In the
decade since the taxable year in issue, petitioner has received
no income from his recording activity.
Substantial income from sources other than the activity may
indicate that the activity is not engaged in for profit. See
sec. 1.183-2(b)(8), Income Tax Regs. A taxpayer with substantial
income unrelated to the activity can more readily afford a hobby.
See Stasewich v. Commissioner, supra. Petitioner earned a
substantial income in 1996 from his employment as an engineer and
had the financial means to make a large expenditure for an
unrelated personal pursuit or hobby.
Finally, the presence of personal motives and recreational
elements in carrying on an activity may indicate that the
activity is not engaged in for profit. Sec. 1.183-2(b)(9),
Income Tax Regs. Although musical and artistic endeavors
generally have personal and recreational elements, a taxpayer’s
personal enjoyment in pursuing the activity is not sufficient to
negate a profit motive if the other factors listed in section
1.183-2(b), Income Tax Regs., indicate such profit motive. See
id. The economic factors discussed above collectively support
the conclusion that petitioner was not engaged in his recording
activity for profit. The personal and recreational elements
inherent in that activity are the most compelling factors in this
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