A partnership in which the taxpayer allegedly invested as a general partner was found not to have a reasonable expectation of profit and, therefore, to not be carrying on a business given that the venture had very limited prospects of success (it was "pitifully undercapitalized", the business in question, i.e., distribution of musical records was difficult to break into and the personnel involved had little experience), and the venture was structured so as to not produce substantial profit for the partnership even if excessive sales forecasts were achieved.
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