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indicate that he or she has a profit objective, even though the
activity is presently unprofitable. Sec. 1.183-2(b)(5), Income
Tax Regs.
Petitioner points out that she has successfully managed
horse shows and trials, worked on farms in Oregon and Montana,
acted as an agent in the sale of cattle, sheep, and horses,
managed a 2,000-head experimental goat herd for the Oregon Health
Sciences Center, raised and sold horses to the American Olympic
Team, and was nominated for the American Olympic Equestrian Team.
Petitioner has had many impressive accomplishments.
However, she has not shown that she operated businesses
profitably or converted similar activities from unprofitable to
profitable. Sec. 1.183-2(b)(5), Income Tax Regs. Petitioner has
not introduced any credible evidence that any of her prior
endeavors were financially successful.
This factor favors respondent.
5. Taxpayer's History of Income or Losses
A history of substantial losses may indicate that the
taxpayer did not conduct the activity for profit. Golanty v.
Commissioner, 72 T.C. at 427; sec. 1.183-2(b)(6), Income Tax
Regs. However, a taxpayer may have a profit objective even if
the activity has a history of losses without any profit.
Bessenyey v. Commissioner, 45 T.C. 261, 274 (1965), affd. 379
F.2d 252 (2d Cir. 1967).
Petitioner's farm generated substantial losses. From 1985
to 1993, petitioner's farm lost $178,486 not counting
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