Elizabeth Giles - Page 42

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          total losses of $441,289.  The size of her losses compared                  
          to only a small profit is not indicative of a profit motive.                
               Petitioner argues that she has the opportunity to earn                 
          a substantial ultimate profit through the sale of                           
          potentially valuable horses.  Petitioner introduced evidence                
          that horses of the bloodlines she used in breeding Borissa                  
          have sold for $300,000, $150,000, $140,000, and $120,000.                   
          Petitioner also testified that some purebred Arabian                        
          stallions have been syndicated for multimillion dollar                      
          values.  A taxpayer’s belief that she could one day sell a                  
          horse for a substantial amount of revenue and a                             
          correspondingly large profit may be indicative of a profit                  
          motive if that belief is adequately supported.  See McKeever                
          v. Commissioner, supra; Dawson v. Commissioner, T.C. Memo.                  
          1996-417.  However, petitioner has never produced a horse of                
          the caliber that would generate such substantial revenue.                   
          Under the circumstances of this case, the possibility of a                  
          highly speculative profit is insufficient to outweigh the                   
          substantial losses and relatively minuscule gain over a 16-                 
          year period.  See McKeever v. Commissioner, supra.                          
               This factor weighs in favor of respondent’s position.                  
               8.   The Financial Status of Petitioner                                
               Substantial income from sources other than the activity                
          may indicate that the taxpayer is not engaged in the                        






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