James C. and Vivian C. Dodge - Page 17

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               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,           





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