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paragraphs, we detail our analysis of the remaining factors found
in the regulations, which weigh in our conclusion.
3. History of Losses
"Although no one factor is determinative of the taxpayer's
intention to make a profit * * * a record of substantial losses
over many years and the unlikelihood of achieving a profitable
operation are important factors bearing on the taxpayer’s true
intention." Golanty v. Commissioner, 72 T.C. at 426; see also
sec. 1.183-2(b)(6), Income Tax Regs. As we have detailed,
petitioner incurred substantial losses in the Schedule F activity
for each of the 10 years that it was carried on at the Arkansas
ranch.
When a taxpayer's losses occur during the startup period of
an activity, the losses have been held not to indicate the
absence of a profit motive. See Engdahl v. Commissioner, 72 T.C.
659, 669 (1979) (unremitting losses were not an indication of
lack of profit motive where years in issue fell within startup
period of horse breeding activity). Petitioners reported
Schedule F losses in connection with the Arkansas ranch beginning
in 1986. They reported losses in connection with the Schedule F
activity beginning in 1987 (when petitioners first claimed a
deduction for horse show expenses) and continuing through
petitioner's move to the Texas ranch in 1996. Petitioner had no
written plan for the Schedule F activity, and he has failed to
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