Taxpayer has been engaged in the general practice of medicine for more than 30 years. In 1991, he took over the operation of his family farm and decided to convert the farm into a cattle farm. He employed a full-time helper on the farm but he himself did much of the physical work. In this endeavor taxpayer had advice of assistance of a local farm agent, an expert cattleman and an expert farm machinery mechanic. Taxpayer raised cattle as well as catfish and quarter horses. However, after encountering technical and demand problems he discontinued the raising of the catfish and horses. He was presently raising thoroughbreds and was confident that this venture would be more profitable. During the period 1991 through 2014, taxpayer farming operation resulted in substantial losses, averaging approximately $15,000 per year. During the taxable years of 2013 and 2014 his farm losses totaled $30,000 and $25,000 respectively. The evidence shows that taxpayer had not made a profit on a year by year basis during this entire period although his testimony to the IRS agent was they he always had operated and still operated his farm with a profit MOTIVE. Can taxpayer deduct the losses?