It is possible to show a loss for more than three years and not be considered a hobby, however it is difficult. The rule is an activity is presumed not to be a hobby if the activity results in a profit in any three of five years. In other words, the activity is automatically not a hobby if there is a profit in three of five years. If there is not a profit in three of five years, you must prove, if challenged by the IRS, that you had a profit motive, ran the activity like a business, etc. The fact that you do not have a profit in three of five years does not automatically make it a hobby.