- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: March 27, 2008