James C. and Vivian C. Dodge - Page 11

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          enable the taxpayer to make informed business decisions.  Burger            
          v. Commissioner, 809 F.2d 355, 359 (7th Cir. 1987), affg. T.C.              
          Memo. 1985-523; Ballich v. Commissioner, supra.                             
               At trial, Mr. Dodge admitted that there were no records kept           
          that would show the expenditures made with respect to each                  
          individual horse.  Without such knowledge, petitioners would have           
          no way of knowing which of their broodmares was producing more              
          profitable foals or which training regimen was successful at                
          increasing the value of the horses.  In addition, petitioners did           
          not even separate the expenses incurred from the horse-breeding             
          activity from the expenses incurred from raising steers.  The               
          lack of any detailed records as to which activity on the horse              
          farm was profitable is an indication that the horse-breeding                
          activity was not carried on for profit.  Ballich v. Commissioner,           
          supra.  Apparently, petitioners retained what they thought were             
          the minimum records necessary to prepare their tax returns.                 
               Petitioners did not advertise their operation or the                   
          availability of their horses in trade magazines, journals, or               
          other publications.  Petitioners argue that they advertised their           
          horses by exhibiting them in horse shows.  While we recognize               
          that horse shows may be one method for advertising horses for               
          sale, petitioners' failure to attempt to reach a larger customer            








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