- 58 - 7. Amount of Occasional Profits--The amount and frequency of occasional profits earned from the activity may also be indicative of a profit objective. Sec. 1.183-2(b)(7), Income Tax Regs. Rance contends that he sold horses during the years in issue where the price exceeded the original cost. The amounts of gain from those sales, however, were minimal ($839 and $230). Moreover, Rance did not report any overall profits from the activity. In other words, there was no showing of profit when considering the overhead, depreciation, etc. The record reflects continual and overwhelming losses. Accordingly, this factor is unfavorable for Rance and LaRhea. 8. Financial Status of the Taxpayer--Substantial income from sources other than the activity, particularly if the activity’s losses generate substantial tax benefits, may indicate that the activity is not engaged in for profit. This is especially true where there are personal or recreational elements involved. Sec. 1.183-2(b)(8), Income Tax Regs. Without counting any farm income Rance and LaRhea had combined gross income (before taking into account a disputed and conceded income issue involving offshore deferred compensation) of $376,439, $421,563, $644,620, and $1,664,811 for the years 1998, 1999, 2000, and 2001. By 2005, Rance and LaRhea’s gross income was $2,739,845, without considering the cutting horse activity. They see this scenario as one that shows that they had the resources to effectively operate the cutting horse activityPage: Previous 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 NextLast modified: March 27, 2008