Barry D. and Suzanne B. Whalley - Page 43

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          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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