- 13 - him to recognize a profit on his investment. He also failed to consult any attorneys or accountants regarding the sponsorship's potential profitability. Third, and even though the absence of a separate checking account and formal books and records does not always indicate that an activity was conducted in an unbusinesslike manner, see Engdahl v. Commissioner, 72 T.C. 659, 666 (1979), under the circumstances herein, we conclude that Dr. DeMattia's record-keeping system was not maintained for the purpose of tracking the business' profitability or conducting the activity in a businesslike manner. Dr. DeMattia's crude record- keeping system was not maintained for the purpose of cutting expenses, increasing profits, and evaluating the overall performance of the investment. See Glenn v. Commissioner, supra. Dr. DeMattia kept no record of the prize money available for each of the tournaments, the amount of money Constant won, or the amount of money to which petitioners were entitled. Compare Krause v. Commissioner, T.C. Memo. 1987-193 (taxpayers documented their son's tournament play to include tour names, cities, sponsoring club, and potential earnings). They did not maintain a budget for the activity. Dr. DeMattia's only concern appears to be the amounts which petitioners could deduct. Furthermore, Dr. DeMattia's failure to make any changes in the method of carrying on the activity in order to increase the activity's potential profitability is also evidence of a lack ofPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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