Joyce E. Hastings - Page 19




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          into her horse activity.  This factor is neutral as to whether              
          petitioner had the requisite profit objective in conducting her             
          horse activity.                                                             
                    6.  The taxpayer’s history of income or losses with               
          respect to the activity.                                                    
               Petitioner’s horse activity did not generate a profit during           
          any of the years from the inception of her horse activity through           
          the year in issue.  We have previously held that the startup                
          phase of an American saddlebred horse breeding activity is 5 to             
          10 years.  Engdahl v. Commissioner, 72 T.C. 659, 669 (1979).  The           
          year in issue falls within this startup phase.  Petitioner                  
          reported increasing losses from 1989 to 1995.  During that                  
          period, 1993 was the only year in which petitioner’s losses                 
          declined from the previous year.  This decline was the result of            
          petitioner’s earning pasturing income of $9,774 and horse show              
          income of $627.50.  Without the pasturing income, petitioner’s              
          losses would have increased in 1993 from the previous year, as              
          was the general pattern for petitioner’s horse activity.  From              
          1989 to 1995, petitioner reported losses in excess of $100,000.             
          In spite of these losses, petitioner never considered abandoning            
          the activity.  Petitioner has not demonstrated that future horse            
          activity income will be sufficient to generate an overall profit            










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