- 17 - 7. Amount of Occasional Profits The amount and frequency of occasional profits earned from the activity may also be indicative of a profit objective. Sec. 1.183-2(b)(7), Income Tax Regs. Petitioners did not report a profit from their horse-breeding activity. See Glenn v. Commissioner, T.C. Memo. 1995-399. 8. Financial Status of the Taxpayer We next consider petitioners' financial status. Sec. 1.183- 2(b)(8), Income Tax Regs. Substantial income from sources other than the activity, particularly if the activity's losses generated substantial tax benefits, may indicate that the activity is not engaged in for profit. This is especially true where there are personal or recreational elements involved. Id. Petitioners had combined gross income, excluding the losses from their horse farm, of $85,216, $88,391, and $103,659 in 1991, 1992, and 1993, respectively. We note that petitioners' income was sufficient to enable them to maintain a comfortable standard of living notwithstanding the losses from the horse farm. 9. Elements of Personal Pleasure The final factor is the personal pleasure derived by petitioners in conducting their activity. Sec. 1.183-2(b)(9), Income Tax Regs. The mere fact that a taxpayer derives personal pleasure from a particular activity does not, per se, show a lack of profit motive. The presence of personal motives may, however,Page: 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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