- 16 - in carrying out the Schedule F activities. However, we are mindful that initially petitioner performed many of the required chores around the North Ranch. At the same time, however, petitioners used the property for hunting and fishing trips, as well as to entertain guests during the holiday season. As a result, we are unable to draw an inference regarding the existence of a profit motive solely from how much time and effort petitioners may have expended working on their Schedule F activities. 4. Expectation That Assets May Appreciate An expectation that assets used in the activity will appreciate may indicate a profit objective. See sec. 1.183- 2(b)(4), Income Tax Regs. Accordingly, a profit motive may be inferred where there are no operating profits, so long as the appreciation in value of the activity’s assets exceeds its operating expenses of the current year and its accumulated losses from prior years. See Golanty v. Commissioner, 72 T.C. 411, 427- 228 (1979), affd. 647 F.2d 170 (9th Cir. 1981); Sullivan v. Commissioner, T.C. Memo. 1998-367, affd. 202 F.3d 264 (5th Cir. 1999); sec. 1.183-2(b)(4), Income Tax Regs. Between 1976 and 1997, the amount of accumulated losses from petitioners’ Schedule F activities exceeded $1.8 million. Petitioners anticipate that they will continue to incur operating losses from these activities in the near future. During the years in issue, the value of the North RanchPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011