Eugene J. Phillips and Barbara A. Phillips - Page 16

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               As to the calculation of income that would be required in              
          future years to produce a profit, Mrs. Phillips testified that              
          she hoped that the horse activity would be profitable within 6 to           
          8 years after petitioners began focusing on Arabians.                       
          Petitioners calculated the cost of each component of their horse            
          activity, categorizing their expenses in their farm books under,            
          inter alia, "Labor Hired", "Feed Purchased", and "Breeding Fees             
          and Veterinary Costs".  Additionally, Mrs. Phillips testified               
          that she calculated the cost of their horse activity on a per               
          horse basis.  Accordingly, petitioners knew the amount of income            
          that would be required in future years.  Finally, Mrs. Phillips             
          testified that she attended seminars on management and marketing            
          at Arabian horse conventions.  Accordingly, we conclude that                
          petitioners carried on their horse activity in a businesslike               
          manner.                                                                     
               As to whether petitioners maintained complete and accurate             
          books and records, respondent contends that petitioners'                    
          financial records are "nothing more than gross chronological                
          lists of expenditures which do not permit a detailed analysis of            
          the various parts of the activity".  Additionally, respondent               
          argues that the records contain many expenditures that are not              
          farm related, e.g., AARP dues, lottery tickets, and air                     
          conditioning for the residence.  As to petitioners' records on              








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