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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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