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Losses sustained because of unforeseen or fortuitous
circumstances beyond the control of the taxpayer do not indicate
that an activity is not engaged in for profit. See sec. 1.183-
2(b)(6), Income Tax Regs. The Court does not believe that the
diminishing of BRVC's gross income, nor the history of losses,
can be attributed to a lackadaisical attitude on the part of
petitioner with respect to the operation of BRVC. In other
words, the income and loss problems of BRVC did not result from a
lack of profit motive by petitioner. Rather, the decrease in
BRVC gross income for 1990 and subsequent years is readily
attributable to a series of untoward events, including the
bankruptcy of Aspri, petitioner's relocation from Louisiana to
Iowa, petitioner's health problems, and, subsequently,
petitioner's period of overseas employment with SOI. Each of
these factors, which the Court has previously discussed in
greater detail, contributed to the waning of BRVC's income. In
addition, the losses can be attributed to some measure of poor
business judgment on the part of petitioner. However, poor
business judgment does not, necessarily, equate with a lack of
profit motive.
In response to each unfortunate circumstance, petitioner
amended the type and magnitude of BRVC activities, indicating her
desire to earn a profit. The Court finds it also notable that
the expenses of BRVC decreased dramatically from 1990 forward, as
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