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profitable, this success may show that the taxpayer has a profit
motive for the activity at issue, even though the activity is
presently unprofitable. Sec. 1.183-2(b)(5), Income Tax Regs. A
taxpayer’s success in dissimilar activities may also indicate a
profit motive. See Daugherty v. Commissioner, T.C. Memo. 1983-
188.
Petitioner argued that his previous work on the family farm
as a teenager indicates that he was previously successful in a
similar activity. Petitioner did describe in detail how much
corn was cropped due to his efforts, but he did not prove that
the family farm was financially successful during those years.
Accordingly, petitioner’s prior work on the family farm does not
support a finding for petitioner.
Petitioner is a licensed CPA and has a legal practice. We
find that petitioner is hard-working and dedicated to his
professional pursuits. Petitioner’s success in a CPA and legal
practice, however, does not equate with petitioner conducting the
farming activity with an honest and actual objective of making a
profit. This factor favors respondent.
6. Taxpayer’s History of Income or Losses
We next examine petitioner’s history of income or loss with
respect to the farming activity. A history of substantial losses
may indicate that the taxpayer did not conduct the activity for
profit. Golanty v. Commissioner, 72 T.C. 411, 427 (1979), affd.
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