Robert Bryan Hudnall and Victoria A. - Page 10




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          landlord had slated the farm for subdivision before it was rented            
          to petitioners.  In addition, the claim that their paying                    
          boarders each assumed the responsibility of feeding, cleaning,               
          grooming, and providing medical services to their own horses                 
          undercuts the notion that petitioners were experienced                       
          equestrians involved in boarding horses for profit, or that they             
          expected their receipts to ever exceed the rental expense of the             
          farm plus supplies and other expenses.  From Mr. Hudnall's                   
          testimony, it seems that petitioners had abandoned any hope of               
          "making it financially" by August 1993, well before the end of               
          the taxable year.                                                            
               The absence of any business documentation whatsoever is                 
          indicative that the activity was not engaged in for profit.                  
          While a taxpayer need not maintain a sophisticated cost                      
          accounting system, the taxpayer should keep records that enable              
          the taxpayer to make informed business decisions.  See Burger v.             
          Commissioner, 809 F.2d 355, 359 (7th Cir. 1987), affg. T.C. Memo.            
          1985-523.  Petitioners provided no agreements, receipts, or any              
          other verification of the existence of clients.  They presented              
          no business plan, canceled checks, business bank account, profit             
          projection, consultants, or record of consultations.  Petitioners            
          state that any and all of these items, if they existed, were                 
          simply "lost", save for a collection notice naming Victoria                  
          Stables as a debtor to Baltimore Gas & Electric.  Petitioners                





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