Martin and Marion Abbene - Page 27

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                  6.    The Taxpayer's History of Income or Loss With Respect                            
                        to the Activity                                                                  
                  A record of substantial losses over several years may be                               
            indicative of the absence of a profit motive.  Golanty v.                                    
            Commissioner, 72 T.C. at 426.  A series of losses during the                                 
            initial or startup stage of an activity, however, may not                                    
            necessarily be an indication that the activity is not engaged in                             
            for profit.  Sec. 1.183-2(b)(6), Income Tax Regs.  Moreover, if                              
            losses are sustained because of unforeseen or fortuitous                                     
            circumstances which are beyond the control of the taxpayer, such                             
            losses would not be an indication that the activity was not                                  
            engaged in for profit.  Id.  Petitioners assert that Blue                                    
            Ribbon's losses were incurred during its startup stage and that                              
            the losses were due, in part, to circumstances beyond their                                  
            control.                                                                                     
                  Although the presence of losses in the early years of an                               
            activity is not inconsistent with an intention to make a profit,                             
            the goal must be to realize a profit on the entire operation,                                
            Bessenyey v. Commissioner, supra at 274, a proposition that                                  
            presupposes not only future net earnings but also sufficient net                             
            earnings to recoup the losses which have meanwhile been sustained                            
            in the intervening years, id.                                                                








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