@Anonymous_ In my 30 years of experience auditing returns, setting up a Section 183 issue is a difficult job. If I recall correctly, I audited and set up the issue 2x. The first was early in my career. It went to tax court. The Govt won the first couple of years, and the TP won after that.
The 2nd time I thought was a "perfect" case. Over 20 years of continuous losses. Even operating at full capacity, losses were still occurring. Issue went to appeals. The appeals officer was retiring, and to clear his desk, many cases were conceded, including this one.
Thus, if a profit is shown once in awhile, I doubt an issue would ever be set up.
But, that's my opinion, not fact.
**Disclaimer: Effort has been made to offer correct information; but due to the discussion forum limitations, the poster disclaims any legal responsibility for the accuracy of the poster's response**
