Ralph E. Wesinger, Jr. and Catherine R. Wesinger - Page 15




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          be a wholly fortuitous result.”  Id.  Given this standard, the              
          Court in Burger found the taxpayers’ annual posting to a ledger             
          from bills and receipts accumulated throughout the year, under              
          headings for revenues and expenses, to be insufficient.  See id.            
          The Court declared the ledger inadequate for any meaningful cost            
          analysis, in part because it failed to allocate costs and                   
          overhead among the animals of the taxpayers’ dog-breeding                   
          operations.  See id.  As a result of this failure, the taxpayers’           
          records did not provide enough information for even determining             
          what the break-even point might be for dog sale purposes.  See              
          id.  The annual posting was also fatal to the taxpayers’                    
          contentions because it precluded frequent monitoring of costs and           
          profitability.  See id.                                                     
               Similar focus on maintaining records useful in making                  
          business decisions is found in Dodge v. Commissioner, T.C. Memo.            
          1998-89, affd. without published opinion 188 F.3d 507 (6th Cir.             
          1999).  In that case the taxpayers kept invoices and receipts for           
          their horse-breeding business and maintained an itemized list of            
          expenses.  See id.  Nonetheless, the Court noted that                       
          “petitioners did not prepare any business or profit plans, profit           
          or loss statements, balance sheets, or financial break-even                 
          analyses for their horse-breeding activity.”  Id.  This lack of             










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