- 12 - written profit or loss statements or balance sheets for the horse-breeding activity. Mr. Morley, however, had a business plan, which was to develop the horse-breeding activity into an enterprise that would support himself and his wife during their retirement years, and he modified the plan in order to reduce expenses and in an attempt to generate a profit. The business plan was evidence by Mr. Morley's actions: Mr. Morley purchased the farm for the horse-breeding activity, bred his horses to produce foals, showed his horses, and advertised his horses for sale. See Phillips v. Commissioner, T.C. Memo. 1997-128. Mr. Morley maintained an itemized list of expenses and a general ledger for the horse-breeding activity. He also consulted with other horse breeders and educated himself about breeding Arabian horses and horse farm management.7 Mr. Morley maintained a separate bank account for the horse- breeding activity. He advertised his horses. Mr. Morley marketed his horses with promotional materials whose color pattern matched those of the University of Tennessee.8 He 7 We have previously held that a taxpayer's informal and continuous consultations with experts knowledgeable about horses and horse-breeding activities demonstrated the taxpayer's intent to engage in horse breeding for profit even though the taxpayer did not conduct a formal market study. Engdahl v. Commissioner, 72 T.C. 659, 668 (1979). 8 Mr. Morley testified that he chose the color pattern for his promotional materials because orange and white were the colors of the University of Tennessee, and he lived in "Big Orange" country. We understand his statement about "Big Orange" (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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