- 26 - expenses for his horse activity of $39,324 for 1990 and $36,039 for 1991. The taxpayer in Arwood v. Commissioner, supra, had losses from 1981 to 1987. He emphasized the business of horse breeding. He had a written business plan and relied on experts for business advice. He believed that his horses would be profitable because his horse's half-brother received $10,000 per breeding, and the sire of his horse received $40,000 per breeding. Petitioner focused little on making money. In Pirnia v. Commissioner, supra, the Commissioner determined a deficiency in income tax for 1982, the year after the taxpayer bought her first horse. The taxpayer relied on experts for financial advice. She expected profits to exceed her losses. She could not rely on income from her physician husband to pay for her horse activity because they were experiencing marital difficulties. She discontinued show activities which were unprofitable to concentrate on breeding. This factor favors respondent. 7. Amount of Occasional Profits, If Any Small occasional profits with large continuous losses do not indicate that the taxpayer had a profit objective. Sec. 1.183- 2(b)(7), Income Tax Regs. Petitioner's losses were large and continuous from 1979 when she started to 1990, the last year in issue. Losses caused by unforeseen circumstances do not necessarily indicate that a taxpayer lacked a profit objective. See EngdahlPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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