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conducting these activities. Petitioner spent a significant
amount of time with the gold mining and treasure hunting
activity. He was not merely an investor who made an occasional
inquiry into the operations; petitioner participated in the daily
operations at the Goliad dig, negotiated contracts, arranged
equipment rentals, and transported equipment. Additionally, many
of the duties performed by petitioner were not activities that
would provide personal pleasure or recreation. For the Goliad
dig, petitioner drove a truck carrying heavy equipment from
Tucson, Arizona, to Goliad, Texas, back and forth twice.
Further, petitioner spent 35 to 40 days working long hours each
night in Goliad in the middle of the summer watching pumping
equipment. Activities of this nature could hardly be called
pleasurable. Petitioner performed a sufficient level of hard,
tedious labor to convince this Court that his primary objective
was to make a profit and that any personal pleasure or recreation
was secondary.
A record of substantial losses over several years may be
indicative of the absence of a profit motive. Golanty v.
Commissioner, 72 T.C. 411, 426 (1979), affd. without opinion 647
F.2d 170 (9th Cir. 1981). Respondent argues that because
petitioner never recovered anything of value from mining and
salvaging, this weighs against a profit motive. We find this
reasoning unpersuasive. If petitioner had engaged in this
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