- 7 - petitioner lacked an actual and honest objective of making a profit. Petitioner presented no credible evidence that he had any real plan for reversing the continuous stream of net farming losses he has reported over the past decade. Petitioner has never consulted an expert on the means by which he could turn a profit, nor has he changed his operating methods in an effort to correct what was obviously not working. This is not surprising considering that petitioner failed to keep any meaningful records that would allow him to gauge the present or future profitability of his activities. Although petitioner maintained ledger sheets recording his expenditures, there is no evidence that he used this information in any constructive way. The following exchange at trial is particularly illuminating in this regard: Q: All right. When do you think that you will buy all of the equipment that you will have to buy, have it all paid off so that you will begin to make money at the ranch? A: I also expected -- I probably -- about '95 or '96. I owe on two more pieces of equipment, one note on each. * * * * * * * Q: All right. But after you pay off the equipment, though, won't -- certain of your expenses, they won't necessarily fall, decrease -- like, for example, the feed expense won't fall, or the supplies expense, or the truck expense. After you pay off your equipment, won't those expenses -- they shouldn't necessarily fall. Is that right? * * * * * * *Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011