- 15 - did not find this factor determinative. We decline petitioner’s invitation. It is for this Court to decide how much weight to attribute to each factor. Petitioner admitted she had never earned a profit while she was involved with her previous thoroughbred horse activities. We have found this as a fact. 6. The Taxpayer’s History of Income or Loss With Respect to the Activity We next examine petitioner’s history of income or loss with respect to the activity. A history of substantial losses may indicate that the taxpayer did not conduct the activity for profit. Golanty v. Commissioner, 72 T.C. 411, 427 (1979); sec. 1.183-2(b)(6), Income Tax Regs. Losses during the initial stage of an activity do not necessarily indicate, however, that the activity was not conducted for profit. Engdahl v. Commissioner, 72 T.C. 659 (1980); sec. 1.183-2(b)(6), Income Tax Regs. Petitioner began her thoroughbred horse activities in 1982 and incurred losses of more than $1.1 million as of 1996, the year at issue. Petitioner contends that we should disregard her history of losses because the small chance to earn a large profit may indicate an intent to earn a profit. We find nothing in the record to support petitioner’s claim. Petitioner never took any steps to put herself in position to earn the substantial profit necessary to recoup her previous losses. She engaged in similar breeding patterns year after yearPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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