Dennis L. and Margaret J. Knudsen - Page 37




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         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.                                     








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