- 16 - T.C. 659 (1979). In light of the instant facts, we find that petitioner's history of losses suggests that he lacked a profit motive in carrying on his horse activity. Accordingly, we find that this factor favors respondent. Amount and Frequency of Occasional Profits The amount and frequency of occasional profits earned from the activity at issue may also be indicative of a profit objective. Sec. 1.183-2(b)(7), Income Tax Regs. Petitioner's horse activity had several sources of income, yet none proved fruitful. While 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 losses are generated, sec. 1.183-2(b)(7), Income Tax Regs, we are convinced that such a likelihood was too remote in the instant case. Accordingly, we find that this factor favors respondent. Petitioner's Financial Status The lack of substantial income from sources other than the activity in question may indicate the existence of a profit motive with respect to such activity. Sec. 1.183-2(b)(8), Income Tax Regs. As petitioner is a successful orthopedic surgeon earning in excess of $250,000 per year, there is little doubt that this factor favors respondent.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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