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other court, and this opinion shall not be treated as precedent
for any other case.
Respondent determined deficiencies in petitioner’s Federal
income taxes for 2002 and 2003 of $3,011 and $6,942,
respectively. The central issue for decision is whether
petitioner’s activities were engaged in with a profit objective
as contemplated by section 183.2 For the reasons discussed
below, we hold for respondent.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ extensive
stipulation of facts and accompanying exhibits.
At the time the petition was filed, Dora Margaret Benson
resided in Colorado.
In 2000 petitioner, a registered nurse, won $4 million in
the Colorado lottery. She received $2,720,000, and to honor her
late mother, set up a memorial/Christian counseling center, the
Lila Osborne Memorial. In addition to running the memorial,
petitioner continued her employment as a nurse.
In 2000 petitioner acquired a building for the memorial.
Petitioner’s family helps her with the building without
compensation. Her sister helps her run the building, and
2 To the extent not discussed herein, other issues are
computational in nature and flow from our decision in this case.
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