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be achieved. See Bessenyey v. Commissioner, 45 T.C. 261, 274
(1965), affd. 379 F.2d 252 (2d Cir. 1967).
From 1992 until 2000, M&S had cumulative losses totaling
$601,183. Petitioner claims that it takes time to reach a
profitable level in a horse breeding business and that M&S was
still in the startup phase. Petitioner has not, however,
provided any evidence or plan that he could ever recoup his prior
losses or make the business profitable. Petitioner did not
provide any evidence that he changed his business plan in order
to make the business profitable. The magnitude of M&S’s
continuing losses in comparison to the revenues M&S received
negates a profit objective.
Elements of personal pleasure or recreation from an activity
may indicate that the activity was not engaged in for profit.
Sec. 1.183-2(b)(9), Income Tax Regs. Petitioner stated in
documents filed with the Superior Court that he supported his
daughter’s interest through the years by providing for the costs
of maintaining her horses and paying for riding competitions.
Petitioner has provided no credible evidence that he owned any
horses other than those used by his daughter for recreational
purposes.
Based on the preponderance of the evidence, and particularly
the large, recurring, and unlikely to be recouped losses, we
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