J. Michael and Susan Reimer - Page 26




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          petitioners ended the activity, show that only losses were                  
          carried.                                                                    
               This factor favors respondent’s position.                              
               (7) The Amount of Occasional Profits, if Any, Which Are                
          Earned.                                                                     
               An occasional small profit from an activity that generates             
          otherwise consistently large losses may not be determinative that           
          the activity is conducted for profit, although an occasional                
          substantial profit may indicate a profit objective.  Sec. 1.183-            
          2(b)(7), Income Tax Regs.  From 1976 through 1998, at least 22              
          years of operation, petitioners’ horse breeding activity has                
          never produced a profit.  See McKeever v. Commissioner, T.C.                
          Memo. 2000-288.                                                             
               Petitioners failed to prove that they earned a profit from             
          the NAS activity from 1990 through 1994, the year they terminated           
          the activity.  However, in reviewing petitioners’ returns in the            
          record, 1992 through 1994, we note that petitioners deducted                
          gross receipts of $4,871, costs of good sold of $7,625, and                 
          expenses of $2,639, thus yielding a net loss of $5,393.                     
               This factor favors respondent’s position.                              
               (8) The Financial Status of The Taxpayer.                              
               The lack of substantial income from other sources may                  
          indicate a profit objective.  Sec. 1.183-2(b)(8), Income Tax                
          Regs.  Conversely, substantial income from other activities may             







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