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of the end of 1990, petitioner had received total rental
income from the Cloudia of $3,305 and had made cash
expenditures amounting to $33,751. Thus, as of the end
of 1990, petitioner had made net out-of-pocket expenditures
of $30,446 on the Cloudia. That amount, plus the original
cost of the Cloudia, $110,000, put petitioner’s total
investment in the sailboat, as of 1990, at $140,446.
Petitioner also testified that at the time he purchased
the Cloudia for $110,000, it would have cost him approx-
imately $60,000 to restore the boat. Thus, considering
petitioner's testimony, we cannot find that petitioner has
shown that he could profit from appreciation in the value
of the Cloudia. See Cannon v. Commissioner, 949 F.2d 345,
352 (10th Cir. 1991) (a record of substantial losses over
many years and the unlikelihood of achieving a profitable
operation are important factors bearing on a taxpayer's
intention), affg. T.C. Memo. 1990-148; Antonides v.
Commissioner, 91 T.C. 686, 696-697 (1988) (“any such
appreciation would have allowed petitioners to do little
more than break even” and “Chartering a yacht to others in
order to afford to keep it through tax savings for one’s
personal enjoyment is not the same as having a profit
objective”), affd. 893 F.2d 656 (4th Cir. 1990); see also
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