Harold W. and Julia A. Kahla - Page 17




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          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.                    






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