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entered into in each tour or their respective potential money
earnings. Constant testified that he had entered 10 to 15 events
in 1996 through 1997, yet again petitioners presented no evidence
regarding Constant's success or ranking in any of these events.
The only evidence presented regarding Constant's performance is
his testimony that he won between four and five tournaments over
a 7-year period. This factor supports respondent's
determinations.
5. Taxpayer's Success on Similar or Dissimilar Activities
Although an activity is unprofitable, the fact that a
taxpayer has previously converted similar activities from
unprofitable to profitable enterprises may show a profit intent
with respect thereto. Sec. 1.183-2(b)(5), Income Tax Regs.
Respondent argues that Dr. DeMattia's lack of involvement in
any similar activity, either in the capacity of a sponsor, agent,
manager, or golf instructor, indicates a lack of profit motive.
In addition, respondent argues that Dr. DeMattia's prior success
in establishing and running a dental practice has no
applicability to his success in this type of activity.
Petitioners concede that Dr. DeMattia had no prior experience or
success in carrying on a similar activity; however, petitioners
portray Dr. DeMattia as an experienced businessman having a
number of successful businesses during his career, including a
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