Sandra J. Brannon - Page 8




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          history of income or losses with respect to the activity; (7) the           
          amount of occasional profits earned, if any; (8) the financial              
          status of the taxpayer; and (9) the elements of personal pleasure           
          or recreation involved.  These factors are not merely a counting            
          device where the number of factors for or against the taxpayer is           
          determinative, but rather all facts and circumstances must be               
          taken into account, and more weight may be given to some factors            
          than to others.  Cf. Dunn v. Commissioner, 70 T.C. 715, 720                 
          (1978), affd. 615 F.2d 578 (2d Cir. 1980).  Not all factors are             
          applicable in every case, and no one factor is controlling.  See            
          Abramson v. Commissioner, 86 T.C. 360, 371 (1986); sec. 1.183-              
          2(b), Income Tax Regs.  Further, the determination of a                     
          taxpayer's profit motive is made on a yearly basis.  See                    
          Commissioner v. Sunnen, 333 U.S. 591, 598 (1948).                           
               On this record, the Court is satisfied that petitioner's               
          activity was not carried on with an actual and honest objective             
          of making a profit.  It is fair to conclude, among other things,            
          that the activity was not conducted in a businesslike manner.               
          Although the Court is satisfied that petitioner was dedicated to            
          the activity, her motivation was primarily her love for horses.             
          Despite years of substantial losses, petitioner had no formal or            
          informal business plan and never sought the advice of experts on            
          how to conduct the activity on a profitable basis.  See Bessenyey           
          v. Commissioner, 45 T.C. 261, 274 (1965) ("the goal must be to              





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