Roderick P. Strickland and Linda G. Strickland - Page 13




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               Each party cited events that occurred after 1996.  We do not           
          consider those events (other than those related to trial                    
          preparation) because those events do not show whether petitioners           
          had a profit objective during the years in issue.  See Lundquist            
          v. Commissioner, T.C. Memo. 1999-83 n.1, affd. without published            
          opinion 211 F.3d 600 (11th Cir. 2000); Estate of Brockenbrough v.           
          Commissioner, T.C. Memo. 1998-454; Gustafson's Dairy, Inc. v.               
          Commissioner, T.C. Memo. 1997-519; Choate Constr. Co. v.                    
          Commissioner, T.C. Memo. 1997-495; cf. Estate of Hutchinson v.              
          Commissioner, T.C. Memo. 1984-55 (events occurring after the date           
          in issue are relevant only if they shed light on the taxpayer's             
          state of mind on the date in issue), affd. 765 F.2d 665 (7th Cir.           
          1985).                                                                      
          B.   Applying the Factors                                                   
               1.   Manner in Which the Taxpayer Conducts the Activity                
               Maintaining complete and accurate books and records,                   
          conducting the activity in a manner substantially like comparable           
          businesses which are profitable, and making changes in operations           
          to improve profitability suggest that a taxpayer conducted an               
          activity for profit.  See Engdahl v. Commissioner, 72 T.C. 659,             
          666-667 (1979); sec. 1.183-2(b)(1), Income Tax Regs.                        
                    a.    Books and Records, Bank Accounts, and Business              
                          Plan                                                        
               Respondent contends that petitioners’ books and records were           
          not adequate because they did not keep them for each horse.                 





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