Elizabeth Giles - Page 40

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          unforeseen or fortuitous circumstances which are beyond the                 
          control of the taxpayer * * * such losses would not be an                   
          indication that the activity is not engaged in for profit.”                 
          Even if unforeseen circumstances beyond petitioner’s control                
          contributed to losses in earlier years, this does not                       
          explain petitioner’s continued losses in 1999, 2000, 2002,                  
          and 2003, nor does it justify extending the long-recognized                 
          5- to 10-year startup stage.                                                
               Petitioner began her horse activity in 1988.  If we                    
          give her the full benefit of the recognized time period, the                
          startup stage of petitioner’s activity ended in 1997.  In                   
          the 6 subsequent years, petitioner reported losses totaling                 
          $111,987, while reporting a profit in just 1 year of only                   
          $209.                                                                       
               Petitioner also argues that her history of losses does                 
          not indicate she lacked a profit motive because the losses                  
          were steadily declining until 2001, when a profit was                       
          achieved.  From 1996 through 2000, petitioner’s losses                      
          declined each year.  In 1999 and 2000, petitioner reported                  
          losses of $22,777 and $17,649, respectively.  In 2001,                      
          petitioner reported a profit of $209.  However, in 2002 and                 
          2003, petitioner reported losses of $27,072 and $23,421,                    
          respectively.  In other words, petitioner’s losses in 2002                  
          and 2003 actually increased relative to her losses in 1999                  






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