- 14 - achieve a later profitable level of operation, bearing in mind, however, that the goal must be to realize a profit on the entire operation, which presupposes not only future net earnings but also sufficient net earnings to recoup the losses which have meanwhile been sustained in the intervening years." In this instance, petitioners sustained substantial losses from their horse-breeding activities for 7 years from 1988 to 1994. The aggregate net losses over the course of these years was $145,510. Losses grew steadily over the first 6 years of operation. Petitioners' operating expenses in each of the years in issue exceeded $21,000, while they have never realized a profit greater than $2,500 on the sale of any one horse. It is, therefore, unlikely that petitioners will generate sufficient profits from the activity to make up for past losses. Despite petitioners' sincere devotion to the operation of Silk Oak, we find this to be highly probative evidence that petitioners do not expect their horse-breeding activity to become profitable. See id. This factor favors respondent. 7. The Amount of Occasional Profits, If Any, Which Are Earned The amount of profits generated in relation to the amount of losses incurred, and in relation to the taxpayer's investment and the value of the assets used in the activity, may suggest the taxpayer's intent. Sec. 1.183-2(b)(7), Income Tax Regs. From 1988 to 1994, petitioners generated a net gain of $6,350 from the sale of four horses and two goats and $400 from the use of their land for grazing. Petitioners' sporadic revenues from thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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