Rodney W. Taras and Linda K. Taras - Page 22

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               Petitioners may have believed that there was a possibility             
          of producing a champion horse that could generate a substantial             
          amount of revenue and correspondingly large profits.  However,              
          the fact that petitioners suffered substantial losses year after            
          year without significantly changing their method of operation in            
          a meaningful way supports the inference that profit was not their           
          primary reason for engaging in this activity.  Ranciato v.                  
          Commissioner, 52 F.3d 23, 26 (2d Cir. 1995), vacating and                   
          remanding T.C. Memo. 1993-536.                                              

          Taxpayers' Financial Status                                                 

               The fact that the taxpayer does not have substantial income            
          or capital from sources other than the activity may indicate that           
          the activity is engaged in for profit.  Sec. 1.183-2(b)(8),                 
          Income Tax Regs.  The legislative history of section 183(a) and             
          (b) indicates a particular concern about wealthy individuals                
          attempting to generate paper losses for the purpose of sheltering           
          unrelated income.  Ranciato v. Commissioner, supra at 25-26; S.             
          Rept. 91-552, at 95-100 (1969), 1969-3 C.B. 423, 484-487.  In               
          this respect, the Senate report focused primarily on farming                
          operations, including specifically the racing of horses, and                
          noted an overall concern about taxpayers with substantial income.           
          S. Rept. 91-552, supra at 95-98, 1969-3 C.B. at 485-486; see also           
          Ranciato v. Commissioner, supra at 25 n.3.                                  






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