- 40 - 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 1999Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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