- 11 - in determining whether the taxpayer entered into the activity for profit, a small chance of making a large profit may indicate the requisite profit objective. Sec. 1.183-2(a), Income Tax Regs. According to the regulations, "it may be found that an investor in a wildcat oil well who incurs very substantial expenditures is in the venture for profit even though the expectation of a profit might be considered unreasonable." Id. Petitioners' family was one of modest means. Petitioners believed that the prospect of producing a champion horse that could generate hundreds of thousands of dollars in revenue and correspondingly large profits seemed to be well worth the risks involved. In essence, the Activity was petitioners' "wildcat oil well". Petitioners actually and honestly believed that if Hot Twist were successful in horse shows, future earnings and profits would be substantial. Mr. Barton confirmed that Hot Twist had the potential to be very successful. We conclude that petitioners' expectation of future profits is consistent with the existence of a profit objective. VII. History of Income and Losses A taxpayer's history of income, losses, and occasional profits with respect to an activity may indicate the presence or absence of a profit objective. Sec. 1.183-2(b)(6), Income Tax Regs. Respondent contends that, because petitioners have incurred losses on their horses in each year, they did not have the requisite profit objective. We disagree.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011