- 20 - e. Change of Operating Methods A willingness to adopt new techniques or abandon unprofitable methods may indicate that a taxpayer has a profit motive. Sec. 1.183-2(b)(1), Income Tax Regs. Petitioner changed her plans for Temptation and Labrette. She stopped entering Temptation in competitions because he was lame. However, she did not adopt a new technique for becoming profitable because she was already breeding Temptation. In fact, petitioner continued to breed Temptation even though the two foals produced by Temptation before the years in issue were far below her expectations. Petitioner changed her plan from breeding Labrette to competing her. Petitioner contends that Labrette's success could help her horse breeding activity become profitable, but we are not convinced that she compared the expenses with the profit potential. This suggests she cared about sports success, not business success. Petitioner testified that petitioners moved to Florida, and then relocated in Florida, to be near dressage activities. Petitioners also point out that petitioner culled her herd in 1987 when she donated three thoroughbred mares to a Gainesville breeding program. However, petitioner did not show how these changes would make her horse breeding activity profitable. f. Advertising The record includes copies of six advertisements for Serenity Farms and Temptation that petitioner placed before thePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011