- 30 - Moreover, petitioners made no showing that Blue Ribbon would have been profitable had the horses not suffered injury. See, e.g., Burger v. Commissioner, 809 F.2d 355 (7th Cir. 1987), affg. T.C. Memo. 1985-523. 7. The Amount of Occasional Profits, If Any, Which Were Earned The amount and frequency of occasional profits earned from the activity may also indicate a profit objective. Sec. 1.183- 2(b)(7), Income Tax Regs. It is uncontroverted that Blue Ribbon never reported a profit from its horse-related activities. The occasional revenues Blue Ribbon generated from horse shows and the provision of riding lessons during the years in issue were de minimis compared to the expenses and depreciation incurred. Nonetheless, petitioners contend that the opportunity to earn a substantial ultimate profit in a highly speculative venture is ordinarily sufficient to indicate that the activity is engaged in for profit even though losses or only occasional profits are actually produced. Id. Additionally, petitioners contend that a small chance of making a large profit may indicate the requisite profit objective. Sec. 1.183-2(a), Income Tax Regs. Petitioners, however, offered no evidence to indicate that Blue Ribbon stood to earn a large or substantial profit during thePage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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