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For the 9 years for which we have petitioner's tax returns,
petitioner's nonfarm income exceeds her farm losses by only
$14,174. Petitioner's farm losses have generated substantial tax
benefits.
This factor favors respondent.
9. Elements of Personal Pleasure
The presence of recreational or personal motives in
conducting an activity may indicate that the taxpayer is not
conducting the activity for profit. Sec. 1.183-2(b)(9), Income
Tax Regs.; see Faulconer v. Commissioner, 748 F.2d at 901;
Jackson v. Commissioner, 59 T.C. 312, 317 (1972) (suffering is
not a prerequisite to deductibility). However, for losses from
an activity to be deductible, the taxpayer's objective in
conducting the activity must be to realize a profit. Bessenyey
v. Commissioner, 45 T.C. at 274.
Petitioner testified that she did not farm for fun, but we
think the objective facts show otherwise. She suggested no
reason other than enjoyment to explain why she conducted an
activity which lost money for 36 out of 37 years.
This factor favors respondent.
C. Conclusion
While no one factor controls, Abramson v. Commissioner, 86
T.C. at 371, we find it significant that petitioner's farm had a
long history of losses, that petitioner derived substantial tax
benefits from these losses, and that petitioner left her farm in
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