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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.
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