- 11 - enable the taxpayer to make informed business decisions. Burger v. Commissioner, 809 F.2d 355, 359 (7th Cir. 1987), affg. T.C. Memo. 1985-523; Ballich v. Commissioner, supra. At trial, Mr. Dodge admitted that there were no records kept that would show the expenditures made with respect to each individual horse. Without such knowledge, petitioners would have no way of knowing which of their broodmares was producing more profitable foals or which training regimen was successful at increasing the value of the horses. In addition, petitioners did not even separate the expenses incurred from the horse-breeding activity from the expenses incurred from raising steers. The lack of any detailed records as to which activity on the horse farm was profitable is an indication that the horse-breeding activity was not carried on for profit. Ballich v. Commissioner, supra. Apparently, petitioners retained what they thought were the minimum records necessary to prepare their tax returns. Petitioners did not advertise their operation or the availability of their horses in trade magazines, journals, or other publications. Petitioners argue that they advertised their horses by exhibiting them in horse shows. While we recognize that horse shows may be one method for advertising horses for sale, petitioners' failure to attempt to reach a larger customerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011