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favor of petitioner’s position. It is important to note,
however, that “An unsuccessful horse-breeding operation
cannot be carried on forever simply because the price of
land in that general area is rising.” Lapinel v.
Commissioner, T.C. Memo. 1989-685.
5. Success of Petitioner in Carrying on Other Similar
or Dissimilar Activities
The fact that the taxpayer has engaged in similar
activities in the past and converted them to profitable
enterprises may indicate that she engaged in the present
activity for profit. Lundquist v. Commissioner, T.C. Memo.
1999-83; De Mendoza v. Commissioner, T.C. Memo. 1994-314;
sec. 1.183-2(b)(5), Income Tax Regs. While petitioner has a
long history of working with horses, she had not previously
engaged in a horse-breeding business. Petitioner runs a
successful dental practice, but she presented no evidence
that she operated her horse activity in a similarly
businesslike manner. See Dodge v. Commissioner, T.C. Memo.
1998-89. Accordingly, this factor is neutral.
6. Petitioners’ History of Income or Losses With
Respect to the Activity
A series of losses during the initial or startup stage
of an activity may not necessarily be an indication that the
activity is not engaged in for profit. Engdahl v.
Commissioner, 72 T.C. at 669; sec. 1.183-2(b)(6), Income Tax
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