- 17 - 10-year startup phase identified above. Accordingly, we find that petitioner's history of losses does not establish that he lacked the requisite profit objective. Seventh, the amount and frequency of occasional profits earned from the activity may also be indicative of a profit objective. Golanty v. Commissioner, 72 T.C. at 427; sec. 1.183- 2(b)(7), Income Tax Regs. Other than the occasional cash awards received from racing his horses, petitioner's horse activity produced no income. However, an opportunity to earn a substantial ultimate profit in a highly speculative venture may be sufficient to indicate that the activity is engaged in for profit even though only loses are generated. Pirnia v. Commissioner, supra; sec. 1.183-2(b)(7), Income Tax Regs. The business of breeding and racing horses is undoubtedly highly speculative and risky. Nevertheless, petitioner aspired to be a successful breeder of horses. It was petitioner's objective to eventually produce horses capable of competing in a triple crown race. Furthermore, petitioner had hoped that his activity would at least be successful enough to facilitate his purchase of a farm from which he could operate the activity. Accordingly, we find that petitioner's failure to make occasional profits is not a determinative factor in this case. Eighth, the lack of substantial income from sources other than the activity in question may indicate the existence of a profit objective. Pederson v. Commissioner, T.C. Memo. 1994-555;Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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