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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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