- 44 - purchased for customers who bought lamb from his ranch, even though he reported Schedule F income of only $475 for 1991. The losses arising from such deductions were used to offset Mrs. Whalley's significant salary from her employment as a police lieutenant. Based on the record and the testimony presented at trial, petitioners' claim that the Schedule F losses were incurred in an activity having a bona fide profit motive exceeds the bounds of credibility. G. Amount of Occasional Profits Earned, If Any If an activity generates only small, infrequent profits and typically generates large losses, the taxpayer conducting the activity may be less likely to have a profit objective. Golanty v. Commissioner, 72 T.C. 411, 427 (1979), affd. without published opinion 647 F.2d 170 (9th Cir. 1981); sec. 1.183-2(b)(7), Income Tax Regs. Petitioners' farm activity has never shown a profit. In fact, petitioners' expenses have greatly exceeded their revenue. For example, for the taxable years in issue, their revenues from the activity were between $475 and $1,050, respectively, while their expenses were between $28,327 and $37,747, respectively. In short, this factor weighs against petitioners' assertion that they operated the farm activity with the intent to turn a profit. H. Taxpayer's Financial Status Substantial income from sources other than the activity may indicate that the activity is not engaged in for profit.Page: 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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