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losses would not be an indication that the activity was not
engaged in for profit. Id.
Although the presence of losses in the early years of an
activity is not inconsistent with an intention to make a profit,
the goal must be to realize a profit on the entire operation, a
proposition that presupposes not only future net earnings but
also sufficient net earnings to recoup the losses which have
been sustained in the intervening years. Bessenyey v.
Commissioner, 45 T.C. 261, 274 (1965), affd. 379 F.2d 252 (2d
Cir. 1967). Petitioner’s losses for 1990 through 1993 exceed
$88,000. The losses were not the result of unforeseen
circumstances such as a natural disaster. There is no evidence
that petitioner attempted to minimize these losses to break even,
let alone recoup past losses. The record suggests that
petitioner was indifferent to the losses. See Peacock v.
Commissioner, supra. This factor weighs against petitioner.
The amount and frequency of occasional profits earned from
the activity may also indicate a profit objective. Sec. 1.183-
2(b)(7), Income Tax Regs. Petitioner never reported a profit
from his fishing activity. The occasional revenues generated
from the sale of fish during the years in issue were de minimis
compared to the expenses and depreciation incurred. The
occasional profits factor weighs against petitioner.
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