Courtney and Brenda Lundquist - Page 26




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          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 Engdahl            


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