- 37 - period, petitioners reported gross receipts of $442,740. The magnitude of petitioners’ losses in comparison with their revenues is an indication that petitioners did not have a profit motive. See Dodge v. Commissioner, T.C. Memo. 1998-89 (citing Burger v. Commissioner, 809 F.2d at 360). This factor favors respondent’s position. 7. The Amount of Occasional Profits Generated by the Activity The amount of profits earned in relation to the amount of losses incurred, the amount of the investment, and the value of the assets in use may indicate a profit objective. See sec. 1.183-2(b)(7), Income Tax Regs. The opportunity to earn substantial profits in a highly speculative venture may be sufficient to indicate that the activity is engaged in for profit even though only losses are produced. See id. In determining whether the taxpayer entered into the activity for profit, a small chance of making a large profit may indicate the requisite profit objective. See id. Petitioners argue that the Court should consider the gross profits realized from the sales of animals. However, petitioners did not introduce evidence that the animals sales produced a profit before operational expenses of ERE were taken into 18(...continued) profit earned during 1989 through 1994.Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 NextLast modified: March 27, 2008