- 17 - exceeded its acquisition costs by $672,443, and the value of the South Ranch exceeded its acquisition costs by $38,048 in 1992 and by $209,948 in 1993 and 1994. However, the appreciation to date in the North and South Ranches, if and when realized, is substantially less than the cumulative losses from petitioners’ Schedule F activities. Moreover, the parties stipulated that both the North and South Ranches were not acquired for speculative appreciation. 5. Past Success in Other Activities We have recognized that a taxpayer’s success in other business activities may indicate a profit motive. See Eldridge v. Commissioner, T.C. Memo. 1995-384; Hoyle v. Commissioner, T.C. Memo. 1994-592. Here, concurrent with the cattle-raising and deer operations, petitioners operated United, a highly profitable business. When asked at trial what he would have done had United not shown a profit, petitioner candidly responded: “I would have just fixed it.” Yet, with respect to the Schedule F activities, petitioner made little attempt to “fix” the continuation of losses. Petitioner’s apparent tolerance of losses from his Schedule F activities is thus contrary to the position he would have permitted at United and suggests a lack of a profit motive with respect to his cattle-raising and deer operations. 6. History of Income or Losses From the Activity A history of losses over an extended period of time may indicate the absence of a profit objective. See Allen v.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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