- 12 - $70,428.52 loss petitioner reported in 1995. Given petitioner's record of losses, we see no possibility that petitioner could recoup his expenditures. Therefore, we find this factor weighs against petitioner. 7. Amount of Occasional Profits Earned, If Any The amount and frequency of occasional profits earned from the activity may also be indicative of a profit objective. See sec. 1.183-2(b)(7), Income Tax Regs. Other than occasional small cash awards, about which petitioner was vague and of which he kept no records, petitioner's automobile drag racing activity produced no income. However, the "opportunity to earn a substantial ultimate profit in a highly speculative venture is ordinarily sufficient to indicate that the activity is engaged in for profit even though losses or only occasional small profits are actually generated." Id. There is no doubt that the automobile drag racing activity was a "highly speculative venture". However, petitioner has not convinced us that he ever had an "opportunity to earn a substantial ultimate profit" from the activity. The small cash awards petitioner received were minuscule in relation to both the losses he incurred and his total investment in the activity, and without a sponsor, petitioner never had an opportunity to earn a substantial ultimate profit. Accordingly,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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