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(net losses in 12 of 12 years); Allen v. Commissioner, 72 T.C. 28
(1979) (net losses in 12 of 12 years); Hoyle v. Commissioner,
T.C. Memo. 1994-592 (net losses in 16 of 16 years). Gold mining,
especially, is an activity in which sustained losses are not
unusual. See Tinnell v. Commissioner, supra (finding the
requisite profit objective in gold mining activity although the
taxpayer had no income from mining during the first 9 years of
the activity and losses in 11 of the subsequent 11 years). Here
petitioner has made a major commitment of his time, energy, and
resources in hopes of locating a valuable mining claim on
property that was mined and abandoned long ago. He goes
prospecting in the inhospitable desert of southern California 3
days out of 7, month after month, and leaves his family behind.
To be able to do this he works 10-hour days, 4 days each week.
He has studied mining, in which he already had a background, and
has devised lightweight equipment that enables him to venture
beyond where vehicles can go. Periodically he peddles gold
nuggets at fairs. Petitioner seeks, and in our judgment
sincerely hopes to find and establish, a claim that is rich
enough to sell to a mining company for exploitation. He seeks
royalties from such exploitation.
We would not voluntarily endure the privations petitioner
endures or spend our time and resources as he has. We doubt that
his business plan is reasonable. But on this record and after
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