context: . Courts that fail to discern a profit motive often specify an alternative explanation for a party's actions.
citation_a.signal: but see
citation_a.identifier: 893 F.2d 656, 660
citation_a.parenthetical: suggesting that the court does not need to pinpoint the likely motivation, as long as it determines on the basis of the Treasury Regulation factors that the activity was not engaged in for profit
citation_a.sentence: But see Antonides v. Commissioner, 893 F.2d 656, 660 (4th Cir.1990) (suggesting that the court does not need to pinpoint the likely motivation, as long as it determines on the basis of the Treasury Regulation factors that the activity was not engaged in for profit).
citation_b.signal: see
citation_b.identifier: 792 F.2d 1258, 1258
citation_b.parenthetical: primary objective of coal mining program was to secure tax benefits rather than to earn an economic profit
citation_b.sentence: See, e.g., Polakof, 820 F.2d at 324 (limited partnership that bought film properties was motivated by a desire to create tax shelters rather than to profit); Thomas, 792 F.2d at 1258 (primary objective of coal mining program was to secure tax benefits rather than to earn an economic profit); Estate of Power v. Commissioner, 736 F.2d 826, 831 (1st Cir.1984) (taxpayer’s horse-breeding activity was engaged in for personal satisfaction, not profit); Eastman, 635 F.2d at 841 (family engaged in horse-breeding in order to utilize the losses from that operation to offset other income).