- 43 - were $21,022 for 1991 and $27,724 for 1992. We find that this factor does not support petitioner's position. F. History of Income or Losses From the Activity A history of losses over an extended period may indicate the absence of a profit objective. Allen v. Commissioner, supra at 34. However, although a long history of losses is an important criterion, it is clear that this factor is not necessarily determinative of a lack of a profit objective. E.g., Engdahl v. Commissioner, supra at 669 (deductions allowed in spite of 12 straight years of losses in a horse-breeding operation). A series of initial or startup losses does not necessarily indicate that the activity was not engaged in for profit. Id.; sec. 1.183-2(b)(6), Income Tax Regs. Moreover, losses sustained because of unforeseen or fortuitous circumstances beyond a taxpayer's control do not indicate that the activity was not engaged in for profit. Engdahl v. Commissioner, 72 T.C. at 669. In this case, petitioners have engaged in their farm activity for approximately 8 years. During those years petitioners' farm activity never made a profit. Petitioners' losses were not due to unfortunate events beyond their control but resulted from their deduction of expenses which in many instances were personal in nature. For example, petitioner testified that in 1991 he deducted $244 worth of wine that hePage: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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