- 42 - 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 thePage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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