- 21 - This factor favors respondent. 10. Petitioners' Other Contention Petitioners point out that petitioners were audited for 1988, and that respondent's agents who conducted that audit did not tell petitioners that they thought petitioners lacked a profit motive for their antique activity. Petitioners contend that this shows that they had a profit motive for their antique activity in 1991 and 1992. We disagree. The Commissioner's failure to raise an issue in a prior audit does not estop the Commissioner from raising it in an audit for a later year. See Knights of Columbus Council No. 3660 v. United States, 783 F.2d 69, 73 (7th Cir. 1986); Hawkins v. Commissioner, 713 F.2d 347, 351-352 (8th Cir. 1983), affg. T.C. Memo. 1982-451. 11. Conclusion We conclude that petitioners did not conduct their antique activity for profit in 1991 and 1992. B. Whether Petitioners' Horse and Rodeo Undertakings Were One Activity Respondent contends that petitioners' horse and rodeo undertakings were two activities. The applicable regulations state that, generally, the most important factors are the degree of organizational and economic interrelationship of the undertakings, the business purposePage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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