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We disagree. Although petitioner has been a successful
entrepreneur in the dental profession, the record does not reveal
that her work in that profession had any bearing on her ability
to conduct the horse activity profitably. See Haladay v.
Commissioner, T.C. Memo. 1990-45 (“wholesale sporting goods
business is sufficiently dissimilar from farming that even if * *
* [the taxpayer’s] business had been a consistently profitable
one, a conclusion that the farming activity should have been
equally profitable would not be warranted.”); see also Dodge v.
Commissioner, T.C. Memo. 1998-89 (taxpayers, who had business
expertise, failed to show that such expertise was used in their
horse activity), affd. without published opinion 188 F.3d 507
(6th Cir. 1999). Moreover, the record does not establish that
she conducted her horse activity in a businesslike manner similar
to that of her dental practice.
This factor favors respondent.
6. Activity’s History of Income and/or Losses
The fact that a taxpayer incurs a series of losses beyond an
activity’s startup stage may indicate the absence of a profit
objective as to that activity unless the losses can be blamed on
unforeseen or fortuitous circumstances beyond the taxpayer’s
control. Sec. 1.183-2(b)(6), Income Tax Regs.; cf. Golanty v.
Commissioner, 72 T.C. at 427 (horse breeding activity may be
engaged in for profit despite consistent losses during the
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