Charles H. Butler and Judith K. Butler - Page 14

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            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 inventory                              





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