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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 purpose
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