Austin L. Mitchell and Rebecca A. Mitchell - Page 14




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          losses for that reason, we believe he had no basis for a bona               
          fide profit expectation because he had no sources of income from            
          the farm.  This factor favors respondent.                                   
               7.   Amount of Occasional Profits, If Any                              
               The amount of any occasional profits the taxpayer earned               
          from the activity may show that the taxpayer had a profit                   
          objective.  Sec. 1.183-2(b)(7), Income Tax Regs.  Petitioner                
          received no revenues from the farm from 1992 to 1998.                       
          Petitioners concede that this factor favors respondent.                     
               8.   Financial Status of the Taxpayer                                  
               The receipt of a substantial amount of income from sources             
          other than the activity, especially if the losses from the                  
          activity generate large tax benefits, may indicate that the                 
          taxpayer does not intend to conduct the activity for profit.                
          Sec. 1.183-2(b)(8), Income Tax Regs.  Petitioners had nonfarm               
          income of $69,704 in 1995, $69,258 in 1996, and $71,050 in 1997,            
          and they claimed Schedule F losses of $8,818, $7,468, and $9,012,           
          respectively.  Petitioner testified credibly that he could not              
          afford to lose money from the farm.  Petitioners did not have a             
          substantial amount of income against which to deduct their                  
          losses, and they did not enter the farming activity to produce              
          losses to offset their income.  See Callahan v. Commissioner,               
          T.C. Memo. 1996-65, affd. 111 F.3d 892 (5th Cir. 1997); Roberts             
          v. Commissioner, T.C. Memo. 1987-182 (taxpayers, who were not               






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