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be sufficient to account for the losses experienced prior to such
appreciation. Accordingly, we find that this factor favors
respondent.
Other Activities
The success of the taxpayer in carrying on other activities
can also be some indication of whether the taxpayer had a profit
motive for the activity in question. Sec. 1.183-2(b)(5), Income
Tax Regs. Petitioner has no experience in similar activities;
however, both his medical practice and his leasing business are
successful profit-oriented activities. In any event, we find
that this factor neither supports nor weakens either party's
position.
Income, Losses, and Occasional Profits
A history of income, losses, and occasional profits with
respect to an activity can be indicative of whether a profit
objective exists with respect to such activity. Sec. 1.183-
2(b)(6), Income Tax Regs. Respondent contends that the history
of losses relating to petitioner's horse activity suggests that
he lacked the requisite profit motive necessary to render section
183 inapplicable. We agree. Petitioner's contention that he
expected to eventually experience a profit is self-serving,
unsupported by the record, and otherwise unrealistic. The
uninterrupted series of losses has been sustained beyond the
period which is customarily necessary to bring a similar
operation to profitable status. See Engdahl v. Commissioner, 72
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