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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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Last modified: May 25, 2011