- 15 - 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,Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011