Geraldine H. Pearson - Page 20

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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           
               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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