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losses that persist over a long period of time and which are not
due to unforeseen circumstances. See Phillips v. Commissioner,
T.C. Memo. 1997-128; Briggs v. Commissioner, T.C. Memo. 1994-125;
Leonard v. Commissioner, T.C. Memo. 1993-472. The antique store
never made a profit. This factor favors respondent.
8. Financial Status of the Taxpayer
Substantial income from sources other than the activity,
causing the losses to generate large tax benefits, may indicate
that the taxpayer is not conducting the activity for profit.
Sec. 1.183-2(b)(8), Income Tax Regs. Petitioners' losses
sheltered a large amount of their income in 1991 and 1992. This
factor favors respondent.
9. Elements of Personal Pleasure
The presence of recreational or personal motives in
conducting an activity may indicate that the taxpayer is not
conducting the activity for profit. Sec. 1.183-2(b)(9), Income
Tax Regs. However, a taxpayer's enjoyment of an activity does
not show that the taxpayer lacks a profit objective if the
activity is conducted for profit as shown by other factors.
Jackson v. Commissioner, 59 T.C. 312, 317 (1972); sec. 1.183-
2(b)(9), Income Tax Regs. Mrs. Brockenbrough likes antiques, and
the record contains little to show she had a profit objective.
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