- 42 - 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 ofPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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