Personal apartment is sublet 4 out of 12 months in 2017 & 2018. Would profit motive be required for Sec. 212/Schedule E deductibility?

Sec. 183 would seem to apply. See analogous example 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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