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industry and also installed street utilities. In 1991,
petitioner terminated Brown Construction and obtained employment
as a field engineer at another company. Petitioner attributed
the short life of his business to the weak economy of the early
1990s. In 1995, petitioner started a second activity, Brown
Enterprises, the gold mining activity at issue.
Petitioner’s unsuccessful business experience is not
particularly helpful to us in determining whether petitioner
engaged in gold mining for profit. The two activities were
fundamentally different. Brown Construction provided consulting
services to the mining industry and the installation of utilities
in streets, employing at any given time up to 25 people. Brown
Enterprises, on the other hand, had no employees; its entire
operation consisted of petitioner’s prospecting for gold in the
desert. We conclude that this factor is neutral or slightly
negative for petitioners, since petitioner’s sole venture in
business for himself, although very different from the gold
mining activity, was not a success.
6. Petitioners’ History of Income or Loss From the
Activity
A series of losses during the initial or startup stage of an
activity may not necessarily be an indication that the activity
is not engaged in for profit. However, where losses continue to
be sustained beyond the period which customarily is necessary to
bring the operation to profitable status, such continued losses,
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