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We do not equate petitioners’ childhood experiences of caring for
a limited amount of cattle with the responsibility associated
with running an entire ranching and farming operation. Further,
petitioners’ experiences in the medical field do not meaningfully
translate into their ranching and farming operations. See
Wesinger v. Commissioner, T.C. Memo. 1999-372; Wilkinson v.
Commissioner, T.C. Memo. 1996-39. Accordingly, this factor also
does not support petitioners’ position.
F. The Activity’s History of Income or Losses and
Amount of Occasional Profits (If Any)
A record of substantial losses over several years may be
indicative of the absence of a profit motive. See Golanty v.
Commissioner, 72 T.C. 411, 426 (1979), affd. without opinion 647
F.2d 170 (9th Cir. 1981). Petitioners have incurred losses
throughout their ownership of the four properties, with
$1,284,349 being incurred between 1986 and 1994. Petitioners
have never earned any profits from the ranching and farming
activities.
Petitioners argue that they incurred losses from normal
startup costs and from unusual market and economic conditions.
Further, petitioners contend that part of their losses can also
be explained by dramatic weather conditions that affected their
Colorado ranch.
We are unpersuaded. Although the Court recognizes that
pecan operations do not immediately become profitable,
petitioners purchased the Kerrville ranch in 1993, but they did
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