James J. Lencke and Janene B. Lencke - Page 20

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          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 Red               




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