- 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 he
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