- 42 - 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 thePage: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
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