- 39 - Regs. However, losses that extend beyond the customary startup stage may indicate that the activity is not engaged in for profit. Engdahl v. Commissioner, supra at 669; sec. 1.183-2(b)(6), Income Tax Regs. From 1988 through 2000, and 2002 through 2003, petitioner reported total Schedule C losses of $441,289. In 2001, petitioner reported a $209 profit from her horse activity, due to the sale of Bogaz for $20,000. Petitioner argues that the history of losses does not indicate she lacked a profit motive because her activity is in the startup stage. This Court has recognized that the startup stage for a horse-breeding activity may be 5 to 10 years. Engdahl v. Commissioner, supra at 669; McKeever v. Commissioner, T.C. Memo. 2000-288; Dodge v. Commissioner, supra. Petitioner argues that her startup stage should be extended because she encountered unforseen circumstances, including the death of two foals in 1991 and 1998, respectively, and the depressed Arabian horse market in the mid-1990s. The applicable regulations do not provide for an extension of the startup stage on account of unforeseen circumstances, and petitioner cites no caselaw to support her argument. Instead, section 1.183-2(b)(6), Income Tax Regs., states: “If losses are sustained because ofPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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