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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 year
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