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A. With the prior years and losses?
Q. Yeah.
A. I would have no idea off the top of my head.
* * *
Q. During 1989 and subsequent years for the business,
did you keep any records that would show the
expenditures made with respect to any individual dog?
A. No, sir.
Q. Okay. Did you make any attempt, since 1989 and
subsequent years, to apportion the expenses to
determine how much each animal was costing you?
A. No, sir.
Since 1989 only five of petitioner's dogs generated any
income, although she owned 28 dogs during 1993, and deducted the
costs of maintaining all of those dogs. Petitioner has an
obvious interest in owning, raising, and showing Pomeranian dogs;
however, we find that during the year in issue, her interest,
which developed when she was a child, was personal in nature and
not based upon the necessary profit motive that would allow for
the activity to be considered a trade or business within the
meaning of section 162(a). Of course, deriving personal
satisfaction out of an activity does not necessarily indicate the
absence of an intent to profit; however, "where the possibility
for profit is small (given all the other factors) and the
possibility for gratification is substantial, it is clear that
the latter possibility constitutes the primary motivation for the
activity." Smith v. Commissioner, T.C. Memo. 1997-503 (citing
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