- 26 - the startup period of their activity, we conclude that this factor is neutral. 7. Amount of Occasional Profits, If Any The amount of any occasional profits the taxpayer earned from the activity may show that the taxpayer had a profit motive. See sec. 1.183-2(b)(7), Income Tax Regs. Petitioners did not make a profit in any year. Petitioners concede that 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. Respondent points out that petitioners had other sources of income available to offset their losses from the horse activity. Respondent points out that petitioners’ losses reduced their taxable income by half in the years in issue. Petitioners’ other sources of income totaled $57,596 in 1994, $60,215 in 1995, and $55,969 in 1996. They spent 40-50 percent of their income on their horse activity in the years in issue. Of their losses, depreciation accounted for only 17.5 percent in 1994, 10.6 percent in 1995, and 9 percent in 1996. See Eisenman v. Commissioner, T.C. Memo. 1988-467 (the taxpayersPage: 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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