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Personal apt. sublet 4 out of 12 mos. in 2017 & 2018. Would profit motive be required for Sec. 212/Sched. E deductibility? Sec. 183 would seem to apply. See analogous ex. of rental situation at T.Reg. 1.183-1(d)1

Here sublet rental income (fmv) - rent expense (due landlord) = 0, so no profit expected either year. Taxpayer will be better off economically than if no subletting, but that doesn't seem to be considered a profit to meet Sec. 212 &183 requirements.

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