- 6 - reasonably suggest that the activity, as petitioner operated it during the years in question, would ever be profitable. Also, petitioner did not maintain the type of books and records that one would generally associate with a trade or business. It appears to us that, while certainly laudable, petitioner’s activity seems to be more an intellectual pastime rather than an actual trade or business. In sum, we do not find that petitioner’s research activity constituted a trade or business or an activity entered into for profit. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011