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(6) The Taxpayer’s History of Income and Losses With
Respect to the Activity, and (7) the Amount of Occasional
Profits, if any, Which Are Earned
Mr. Lamb reentered the tuna fishing business in 1988, and
this activity generated the following losses:
Year Loss
1988 $22,349
19891 --
1990 21,863
1991 15,053
1992 11,191
1993 11,212
Total $81,668
1Mr. Lamb did not conduct any commercial fishing activity
during 1989 or after 1993.
A record of substantial losses over several years is
generally indicative of the absence of a profit objective.
Golanty v. Commissioner, 72 T.C. at 426. The record indicates
that Mr. Lamb purchased the Lu-Joy and reentered the tuna fishing
business in 1988 with the belief that he “was going to make a
killing”, given the rising prices for tuna. The record also
clearly indicates that Mr. Lamb was an accomplished fisherman
with many years of experience. We do not believe that a
fisherman with Mr. Lamb’s expertise would have caught only one
fish in 2 years if he had been healthy. Unfortunately, Mr.
Lamb’s eyesight, which is obviously so vital to a harpoon
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