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indicate that the activity is not engaged in for profit.
Although a series of losses at the beginning of an activity does
not necessarily mean that the activity was not entered into for
profit, such a string of losses weighs against a profit intent
absent unforeseen or fortuitous circumstances beyond the
taxpayer's control (e.g., fire, disease, theft). A string of
substantial losses over many years and the unlikelihood of
turning a profit are important factors in ascertaining intent.
Bessenyey v. Commissioner, 45 T.C. 261, 274 (1965), affd.
379 F.2d 252 (2d Cir. 1967); see also Cannon v. Commissioner,
T.C. Memo. 1990-148, affd. 949 F.2d 345 (10th Cir. 1991).
The start-up period for a cow-calf operation is 5 to 7
years. See Hrdlicka v. Commissioner, T.C. Memo. 1985-403.
Petitioners reported a loss from their cow-calf operation for
16 years in a row from 1979 to 1994, totaling $1,003,746.
Petitioners have not established that any of these breeding
losses was due to unforeseen or fortuitus circumstances beyond
their control or that this stream of losses was likely to change.
Petitioners have also offered no evidence, other than their
subjective testimony, to support their assertion that these
losses were from a business.
Even if we were to assume, arguendo, that petitioners had a
profit objective before the subject years, we would still not be
persuaded that they retained this objective during the subject
years. In order to fall outside the purview of section 183, one
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