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business could stay afloat at that price level. As was the case
with the cattle ranch, turning a profit while employing such
techniques would best be characterized as merely fortuitous.
Next, as to expertise, there again appears to have been no
basic investigation of the economic aspects of the business.
There also was no evidence that petitioner had any experience in
the rental of airplanes.
Furthermore, the time and effort expended by petitioner on
his rental business was negligible. No advertising or marketing
was undertaken. The plane was rented only to petitioner’s own
business, SRMC. Moreover, between 65 and 75 percent of the
plane’s total usage, for the years as to which losses were
disallowed, was by petitioner for traveling to and from his
ranch. With such a comparatively small amount of time available
for rental, a bona fide intention to profit seems rather far-
fetched.
In addition, no appreciation could have been expected
because vehicles, including aircraft, typically depreciate rather
than increase in value.
The only factors weighing to any significant degree in favor
of a profit motive are those addressing history of losses and
occasional profits. Losses were reported in 1990, 1992, 1993,
and 1997, but petitioner’s aircraft-rental operations earned a
profit in 1991, 1994, 1995, and 1996. Such profits could be
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