- 22 - 748 F.2d 890, 893 (4th Cir. 1984), revg. and remanding T.C. Memo. 1983-165. The losses petitioner claimed relating to the Feadship generated significant claimed tax savings, which, if allowed, would offset income from petitioner’s unrelated medical practice. History of Income or Losses Substantial losses over a number of years suggest a lack of profit objective. Sec. 1.183-2(b)(6), Income Tax Regs. If, however, losses result because of unforeseen circumstances beyond the control of a taxpayer, the losses may bear less on the question of profit objective. Id. Chartering the Feadship resulted in losses to petitioner for all 3 years at issue. The excessive costs relating to the repair and restoration work on the Feadship may have been a surprise to petitioner, but good faith, diligent, and timely investigation into the condition of the Feadship and into the nature of the luxury yacht charter business would have eliminated most of this surprise and would have provided to petitioner information upon which he would have been able to make a reasoned and calculated decision about whether to proceed further. By 1995, petitioner’s costs associated with the Feadship were so high that he should have known that charter of the Feadship would not generate income sufficient to cover those costs. Further, in 1995, 1996, and 1997, while the Feadship was available for charter, the Feadship also was for sale at anPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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