- 11 - qualified individuals, such as trainer Rusty Hadden, to develop her Appaloosas. We find that this factor favors petitioner. Expectation That Assets May Appreciate An expectation that assets used in the activity will appreciate in value may indicate a profit objective. Sec. 1.183- 2(b)(4), Income Tax Regs. Petitioner clearly expected her broodmares and their offspring to appreciate in value. We find that this factor favors petitioner. Past Success in Other Similar or Dissimilar Activities The fact that the taxpayer has engaged in similar activities in the past and converted them from unprofitable to profitable enterprises may indicate that she is engaged in the present activity for profit, even though the activity is presently unprofitable. Sec. 1.183-2(b)(5), Income Tax Regs. Petitioner successfully operated a billing service for a number of years until her customers retired and/or moved out of the area. We find that this factor favors petitioner. Taxpayer's History of Income and Losses Petitioner has never had a profitable year. She has had sporadic sales over the years. Her net losses have continued beyond the customary startup period for a horse breeding and selling activity. We find that the circumstances within the Appaloosa market and her personal setbacks do not fully explain her long series of losses. Cf. sec. 1.183-2(b)(6), Income Tax Regs. We find that this factor favors respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011