Taxpayers who seek to claim deductions for ordinary and necessary expenses paid or incurred in carrying on a trade or business or for the production or collection of income or for the management, conservation, or maintenance of property held for the production of income must show a profit motive. Without a profit motive behind the activity, in general, a taxpayer is barred from claiming deductions for activities not engaged in for profit under Section 183(a) of the Internal Revenue Code. The big issue is whether an activity is a trade or business (or one for investment) or is rather merely a hobby. A recent Tax Court case illustrates the difference between a profit motive and a hobby.  

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