- 20 - transactions through their personal bank account and Mr. Lencke's former insurance bank account. Petitioners argue that their record-keeping system for Red Caboose was complete and accurate, and thus evidence of their profit motive, because Mr. Lencke used the same system for his insurance activity. We do not find their reasoning persuasive. Even if the record-keeping system used by petitioners for Red Caboose was an adequate record-keeping system for Mr. Lencke's insurance activity, which is an issue we do not address, it does not follow that such a system was a complete and accurate record- keeping system for a model railroad activity. It is significant that petitioners did not have a concrete plan for improving the profitability potential of Red Caboose. During each year in issue, and in later years, they sustained sizeable losses in connection with Red Caboose. In 1990 they reported a loss of $29,818; in 1991 they reported a loss of $17,911; and in 1992 they reported a loss of $24,058. However, in spite of these large losses, they failed to substantially change their method of operating Red Caboose. Other than staying at less expensive hotels and eating at less expensive restaurants while they were attending model railroad shows, they did little, if anything, to reduce Red Caboose's operating expenses. Moreover, they were not successful in implementing remedial measures to increase Red Caboose's revenues. For example, they did not consider installing a separate telephone line for RedPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011