Elizabeth Giles - Page 42

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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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