Jun Xia - Page 7

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          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.                          






















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