N. Thomas Ryan - Page 15

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               Neither petitioner nor his wife has ever been involved in              
          any other entrepreneurial ventures.  This is a neutral factor.              
                    6.  The Taxpayer’s History of Income or Losses With               
                    Respect to the Activity                                           
               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 (horsebreeding activity may be                 
          engaged in for profit despite consistent losses during the                  
          startup phase).                                                             
               Petitioner attributes part of his losses to a depressed                
          market due to the September 11, 2001, terrorist attacks.                    
          Petitioner testified that, before 2001, he could have received              
          $10,000 to $20,000 dollars for a 3-year-old foal, but in 2004,              
          petitioner believed that a 3-year-old foal would yield a maximum            
          of $10,000 to $12,000 dollars.  Petitioner had several years of             
          losses because he did not have any 3-year-old foals to sell.                
               Petitioner had losses totaling $93,893 for tax years 1997,             
          1998, and 1999 combined.  While the events of September 11, 2001,           
          may have depressed the market, petitioner did not make any sales            
          or have any foals available for sale during the years in issue.             
          There is no evidence of any gross receipts from this activity at            







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