Lee W. Yates and Wendy S. Yates - Page 8

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          question were engaged in for a profit.  Sec. 1.183-2(b)(1),                 
          Income Tax Regs.  The record indicates that petitioners                     
          maintained thorough accounts of revenue and expenditures                    
          connected with Silk Oak's operations, using a computer program              
          recommended by their accountant.  Petitioners also maintained               
          separate accounts for Silk Oak's finances.  Respondent concedes             
          that petitioners maintained books and records in a businesslike             
          manner.                                                                     
               Petitioners' detailed bookkeeping does not, by itself,                 
          indicate an intent to generate a profit.  Golanty v.                        
          Commissioner, supra at 426.  A lack of profit motive may exist              
          where a taxpayer fails to abandon unprofitable methods, change              
          operations, or adopt new techniques in an attempt to improve                
          profitability.  Sec. 1.183-2(b)(1), Income Tax Regs.                        
          Accordingly, the maintenance of detailed books and records may              
          reveal the mere "trappings" of a profit business, particularly              
          when a taxpayer fails to produce income statements, profit plans,           
          or business plans created to alter operations in an attempt to              
          reverse mounting losses.  Osteen v. Commissioner, T.C. Memo.                
          1993-519, affd. in part and revd. in part 62 F.3d 356 (11th Cir.            
          1995).                                                                      
               In this instance, petitioners commenced operation of Silk              
          Oak with neither expertise in running a profitable ranch nor a              
          detailed written plan fashioned to enable them to earn a profit.            
          Petitioners, however, contend that before conducting any ranching           




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