- 13 - Conclusion For the reasons discussed above, and on the basis of all of the facts and circumstances present in this case, we hold that petitioner was not engaged in any of the activities at issue with the profit objective contemplated by section 183. See also Rule 142(a); INDOPCO, Inc. v. Commissioner, supra at 84; Welch v. Helvering, supra at 115. Accordingly, we find for respondent. To reflect our disposition of the disputed issues, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14Last modified: March 27, 2008