- 38 - 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 advertisePage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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