Wednesday, March 21, 2012
Barker v. Commissioner, T.C. Memo. 2012-77 (Mar. 20, 2012):
We do not fault petitioner's strong passion for Mars exploration and its related technology. We believe he pursues a noble cause that one day could provide benefits to all humanity. However, passion is not synonymous with a profit motive. In the absence of other factors supporting his passion, we do not believe this factor supports a finding of a profit motive.