- 24 - petitioners’ farm improvements had appreciated $24,000 by 1998. We assume the vast majority of this appreciation occurred as the improvements were made because they were self-constructed. Petitioner expected that, for each dollar he spent on the farm improvements, it would increase the value of petitioners’ property by $2. Also, as stated above, petitioners’ horses and farm improvements appreciated significantly in value during the years in issue. Petitioners had a bona fide expectation of future profit. See Estate of Baron v. Commissioner, 83 T.C. 542, 553 (1984), affd. 798 F.2d 65 (2d Cir. 1986) (reasonable or realistic expectation of profit is not required if taxpayer has bona fide expectation of profit); Dreicer v. Commissioner, 78 T.C. at 643-645. We are convinced that petitioners had appreciation in their horses and farm improvements during the years in issue of approximately the same order of magnitude as their losses in those years. Thus, we need not decide whether petitioners’ residence and land also increased in value. Accordingly, this factor favors petitioners. 5. Taxpayer's Success in Other Activities The fact that a taxpayer previously engaged in similar activities and made them profitable may show that the taxpayer has a profit objective. Sec. 183-2(b)(5), Income Tax Regs. Petitioners have not engaged in similar activities for profit,Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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