- 16 - profits are occasional and small or nonexistent. See id. Horse breeding and racing are highly speculative ventures. Petitioners did not report a profit in any of the years they carried on the horse-related activity. 8. Petitioners’ Financial Status Substantial income from sources other than the activity, particularly if the losses from the activity generate substantial tax benefits, may indicate that the activity is not engaged in for profit, especially if there are personal or recreational elements involved. See sec. 1.183-2(b)(8), Income Tax Regs. Petitioner earned $52,815 in 1993, and Mr. Pitts received $11,659 in Social Security benefits. Petitioners derived some tax benefits from their claimed losses. 9. Elements of Personal Pleasure The mere fact that a taxpayer derives personal pleasure from a particular activity does not show a lack of profit motive. See sec. 1.183-2(b)(9), Income Tax Regs. The presence of personal motives may indicate that the activity is not engaged in for profit. This is especially true when there are recreational elements involved. See id. It is not clear from the record whether petitioner rode the horses. We assume that Mr. Pitts could not because of his disability. It is clear, though, that petitioners enjoyed horses and have a long history of working with them.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011