- 19 - 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 profitPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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