- 24 - carefully reviewed monthly reports and held his managers accountable for variances from the business plan and budget A change of operating methods, adoption of new techniques, or abandonment of unprofitable methods is further evidence of petitioners' profit motive. Eldridge v. Commissioner, T.C. Memo. 1995-384; sec. 1.183-2(b)(1), Income Tax Regs. Here, petitioner implemented numerous changes in operation to try to improve profitability. When petitioner acquired Flying H, he began his operation with 20 longhorn cattle. Thereafter, he and his advisers determined that the longhorn were not profitable and decided not to expand that aspect of the business. Moreover, in an effort to cut losses, they put the longhorn to work as lead cattle. In 1987, Dr. Haaland determined that operating under rate- of-gain contracts was ruining the pastures' potential for long- term profits and recommended that petitioner take over the direct management of the ranch. Petitioner, following Dr. Haaland's advice, cut back on grazing, which gave the pastures a chance to recover. In the short-term, however, this meant that Flying H was not operating at its maximum cattle capacity, and therefore it was not maximizing its short-term earning potential. In 1993, after running a stocker operation for several years, petitioner and his advisers determined that it would be more profitable to combine the stocker operation with a calf-cow operation, so that in 1995 it ran 1,050 stockers and 265 cows.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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