17 A taxpayer's involvement in similar activities in the past, especially where he has converted them from unprofitable to profitable operations, may indicate a profit objective, despite a currently unprofitable activity. Sec. 1.183-2(b)(5), Income Tax Regs. There is no evidence that petitioner has ever operated a ranch before, nor that he has had any profit from any ranching, farming, or guest cottage activities. This factor favors respondent. 6. Petitioner's History of Income or Losses Neither startup losses nor losses that result from unforeseen circumstances necessarily show that the taxpayer lacked a profit objective. Engdahl v. Commissioner, supra at 669; sec. 1.183-2(b)(6), Income Tax Regs. However, losses incurred over many years with little likelihood of future profits indicate a lack of profit objective. Golanty v. Commissioner, 72 T.C. at 426. Since its inception and through 1992, petitioners have consistently reported significant expenses and negligible gross income, thus producing losses from the ranching activity. The expenses claimed for the years the parties considered (1986-92) total $768,804, while the total income over the same period was only $52,345. Petitioner argues that considerable expenditures were incurred getting the ranch in working order, buying and training the horses, and that the return for these expenditures would not be seen until several years later. We are notPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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