- 15 - he did not abandon unprofitable methods. He offered no evidence of how comparable profitable businesses worked. Petitioners contend that petitioner operated his horse racing and breeding activity for profit because he operated Westfield Gage and his horse activity in the same manner. We disagree. Petitioner did not operate Westfield Gage and his horse activity in the same manner. He said that if Westfield Gage had lost money, he would have gotten advice on how to fix it. When Westfield Gage began to lose money because Pratt and Whitney asked him to lower his charges to them, petitioner convinced Pratt and Whitney to give Westfield Gage additional business so that it could again be profitable. Petitioner took no similar action to try to make his horse activity profitable. Petitioners contend that petitioner operated his horse racing and breeding activity like the taxpayer did in Arwood v. Commissioner, T.C. Memo. 1993-352. We disagree. The taxpayer in Arwood v. Commissioner, supra, had losses from 1981 to 1987. However, he had a written business plan which he adjusted in response to changed circumstances, and he consulted and relied on experts for business and financial advice. He believed that his horses would be profitable because his horse's half-brother received $10,000 per breeding and the sire of his horse received $40,000 per breeding. Petitioner did not have a written plan or financial analysis of the profit potential of his activity. This factor favors respondent.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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