Richard J. and Melodie D. McKeever - Page 42




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                  7.  Amount of Occasional Profits                                                     
                  The amount of profits earned in relation to the amount of                            
            losses incurred, the amount of the investment, and the value of                            
            the assets in use may indicate a profit objective.  See sec.                               
            1.183-2(b)(7), Income Tax Regs.  The opportunity to earn                                   
            substantial profits in a highly speculative venture may be                                 
            sufficient to indicate that the activity is engaged in for profit                          
            even though only losses are produced.  See id.  In determining                             
            whether the taxpayer entered into the activity for profit, a                               
            small chance of making a large profit may indicate the requisite                           
            profit objective.  See id.                                                                 
                  In 11 years of operation, petitioners’ horse activity has                            
            never turned a profit.  Classic fino horses that win at the                                
            national level can sell for prices in excess of $250,000.                                  
            Petitioners claim to be focusing on that market and hope that one                          
            day their herd will produce such a horse.  Petitioners’ professed                          
            belief that a champion horse could generate a substantial amount                           
            of revenue and correspondingly large profits may be indicative of                          
            profit motivation.  See Dawson v. Commissioner, T.C. Memo. 1996-                           
            417.                                                                                       
                  Under the circumstances of this case, however, we agree                              
            with respondent that the possibility of a speculative profit is                            
            insufficient to outweigh the complete absence of profits over a                            
            period of 11 years.  During the years at issue, none of                                    






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