- 14 - an activity was conducted in a manner substantially similar to comparable businesses that are profitable, and where changes were attempted in order to improve profitability, a profit motive may be indicated. Engdahl v. Commissioner, 72 T.C. 659, 666 (1979); sec. 1.183-2(b)(1), Income Tax Regs. There is little evidence that petitioners operated their farm with the expectation of profitability. Petitioner husband argues that he has maintained records for his activities. Petitioner husband kept records consisting of receipts that were segregated in folders according to each Schedule F line item. Petitioners did not maintain a separate checking account or a system of ledgers which would have provided a basis for ascertaining revenue and expenses. Significantly, there is nothing in the record showing that petitioners conducted an analysis or investigation of the profitability of farming in their area. Finally, and more significantly, petitioners did not prepare an analysis of the revenues and expenses that their property could achieve with more livestock (either cattle or sheep) to determine whether it could then be operated in a profitable manner. Petitioners did not demonstrate that the manner in which they conducted the farming operation was reasonably calculated to produce a profitable return. Although petitioners reported their farming activity as "General Livestock", there was no inventoryPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011