Barry D. and Suzanne B. Whalley - Page 38

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          Commissioner, supra at 666-667.  For example, keeping books and             
          records related to an activity may be indicative of a profit                
          objective.  Id.; sec. 1.183-2(b)(1), Income Tax Regs.  In                   
          addition to maintaining records, advertising an activity may                
          indicate a profit objective.  Engdahl v. Commissioner, supra.               
          Also, adapting new techniques and abandoning inefficient methods            
          may support the conclusion that the taxpayer possessed the                  
          requisite profit objective.  Allen v. Commissioner, supra at 35;            
          sec. 1.183-2(b)(1), Income Tax Regs.                                        
               Here, petitioners failed to conduct their farm activity in a           
          businesslike manner.  They did not maintain complete and accurate           
          books, nor did they keep contemporaneous records of receipts and            
          expenditures arising from their farm activity.  In many instances           
          they failed to provide respondent with the evidence of payment in           
          the form of canceled checks, invoices, or receipts for expenses             
          claimed, or evidence of business purpose.  Petitioners' notations           
          on checks as to the business purpose of such checks were written            
          after the fact; i.e., at the end of the year in which the                   
          expenses were allegedly incurred.  In fact, in many instances,              
          petitioner was not quite sure what went into some of the expenses           
          claimed.                                                                    
               Advertising an activity may be indicative of a profit                  
          motive.  In 1991, however, the only advertising expense incurred            
          by petitioners was for a local newspaper ad listing a cockatiel             
          and a ram for sale.  In 1992, petitioners did not advertise                 




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