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those activities were profitable, those small amounts of receipts do
not offset the large losses that petitioners had each year from 1980
to 1995. This factor favors respondent.
8. Financial Status of the Taxpayer
The receipt of a substantial amount of income from sources
other than the activity, especially if the losses from the activity
generate large tax benefits, may indicate that the taxpayer does not
intend to conduct the activity for profit. See sec. 1.183-2(b)(8),
Income Tax Regs. Petitioners had nonfarm income of $154,309 in
1995. Their nonfarm income exceeded their farm losses from 1980 to
1997. See Rinehart v. Commissioner, T.C. Memo. 1998-205 (taxpayers
lacked a profit objective where taxpayer earned between $166,000 and
$170,000 per year during the years in issue). Petitioners’ losses
sheltered a large amount of their income in 1995. This factor
favors respondent somewhat.
9. Elements of Personal Pleasure
The presence of recreational or personal motives in conducting
an activity may indicate that the taxpayer is not conducting the
activity for profit. See sec. 1.183-2(b)(9), Income Tax Regs. A
taxpayer's enjoyment of an activity does not show that the taxpayer
lacks a profit objective if the activity is, in fact, conducted for
profit as shown by other factors. See Jackson v. Commissioner, 59
T.C. 312, 317 (1972); sec. 1.183-2(b)(9), Income Tax Regs. However,
if the possibility for profit is small compared to the possibility
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