- 19 - Petitioners contend that petitioner's books were like those kept by the taxpayer in Phillips v. Commissioner, T.C. Memo. 1997-128, whom we held conducted a horse activity for profit. We disagree. In Phillips, the taxpayers had a business plan. They calculated the costs per horse per month. They estimated when their horse activity would become profitable. They performed a detailed analysis of their horse activity and planned each of their horses' breedings. Petitioner did not do so. Phillips also differs from this case because the taxpayers in Phillips made significant changes in their operating methods by adding horse boarding, training, teaching classes, and operating a tack shop to sell equipment. d. Commingling of Funds Commingling of funds suggests that the activity is a hobby rather than a business for profit. See Rinehart v. Commissioner, T.C. Memo. 1998-205; Ballich v. Commissioner, T.C. Memo. 1978- 497. Petitioner paid the expenses of the horse breeding activity from petitioners' personal account. She had no separate bank accounts for the horse breeding activity. Petitioners used a credit card for her horse activity. However, she did not say that she paid all of the horse activity expenses with the credit card, and she paid the credit card bills from petitioners' personal checking account. She did not segregate income from her horse activity.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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