Yes, I admit to all of the above - including what a 'short put' is, since I do a lot of golfing. But, any publicity is good publicity!!
- I refuse to admit I EVER lived in Pecos, ROTFLMAO.
Yeah...and the judge told me he and his 'experts' had at one time looked into "covered calls", and determined that there was no merit to any great potential.
Perhaps now I SHOULD consider the following:
"For a taxpayer to deduct expenses of an activity pursuant to section 162, the taxpayer must show that he or she engaged in the activity with an actual and honest objective of making a profit. Whether a taxpayer had an actual and honest profit objective is a question of fact to be resolved from all relevant facts and circumstances."
Section 1.183-2(b), Income Tax Regs., provides a nonexclusive list of factors that should be considered in determining whether an activity is engaged in with the requisite profit objective. The nine factors are: (1) The manner in which the taxpayer carries on the activity; (2) the expertise of the taxpayer or his or her advisers; (3) the time and effort expended by the taxpayer in carrying on the activity; (4) the expectation that the assets used by the taxpayer in the activity may appreciate in value; (5) the success of the taxpayer in carrying on other similar or dissimilar activities; (6) the taxpayer's history of income or losses with respect to the activity; (7) the amount of occasional profits, if any, which are earned; (8) the financial status of the taxpayer; and (9) whether elements of personal pleasure or recreation are involved. No single factor, nor the existence of even a majority of the factors, is controlling, but rather it is an evaluation of all the facts and circumstances in the case, taken as a whole, which is determinative. These factors are not applicable or appropriate in every case. See Abramson v. Commissioner, 86 T.C. 360, 371 (1986)."
"Based upon the above factors as applied to circumstances of this case, we find that petitioner did not engage in the consulting activity for profit."
Perhaps I should now go back to the judge and ask for my deductions to be allowed - not that I can do much about my picture!
In any case, what's the point in continuing with
www.kingdomcapital.com - except that if you follow my lead, at about this time next year you will be running riot with your investments. Gilbert
paysense
