- 15 - horses. It is necessary, however, that the objective be to realize a profit on the entire operation. Bessenyey v. Commissioner, 45 T.C. 261, 274 (1965), affd. 379 F.2d 252 (2d Cir. 1967). This would require future net earnings and appreciation sufficient to recoup the $622,301 of losses reported for 1983 through 1995. Petitioners failed to produce any evidence to show that their activity had a reasonable chance of recovering losses reported. 5. Taxpayer's Success in Similar or Dissimilar Activities We next consider petitioners' prior experience in similar or dissimilar activities. Sec. 1.183-2(b)(5), Income Tax Regs. Although an activity is unprofitable, the fact that a taxpayer has previously converted similar activities from unprofitable to profitable enterprises may be an indication of a profit motive with respect to the current activity. Id. Mrs. Dodge started an accounting and service business in 1991 that generated a profit during the years at issue. Mr. Dodge operated a successful law practice during the years in issue. Petitioners had successful business-type experience. Petitioners did not show that their acquired business expertise was used in the horse activity. 6. The Activity's History of Income and/or Losses An important consideration is petitioners' history of income and/or losses with respect to their horse-breeding activity. Sec. 1.183-2(b)(6), Income Tax Regs. Losses continuing beyondPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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