- 16 - petitioners' argument that the losses were the result of startup expenses to be without merit. In addition, petitioners assert that their losses were the result of "unforeseen or fortuitous circumstances * * * beyond * * * [their] control". Sec. 1.183-2(b)(6), Income Tax Regs. Petitioners assert that the disease PRA caused an unanticipated increase in expenses in 1992 because they were required to purchase new stock for breeding. This argument fails for two reasons. First, PRA did not have a significant impact on petitioners' dog-breeding activity during the taxable years in question. Petitioners did not know that any of their dogs even had PRA until 1994. Second, as already noted, petitioners' losses were largely the result of the high cost of dog boarding and handling, and not from the purchase of breeding stock. 7. Amount of Occasional Profits The amount and frequency of occasional profits earned from the activity may also be indicative of a profit objective. Sec. 1.183-2(b)(7), Income Tax Regs. Given that petitioners have never reported a profit on their dog-breeding activity, we find that this factor supports a finding that the dog-breeding activity was not carried on for profit. Glenn v. Commissioner, T.C. Memo. 1995-399. 8. Financial Status of the Taxpayer We next consider petitioners' financial status. Sec. 1.183- 2(b)(8), Income Tax Regs. Substantial income from sources otherPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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