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number of factors for or against the taxpayer is determinative,
but rather all facts and circumstances must be taken into
account, and more weight may be given to some factors than to
others. Taube v. Commissioner, 88 T.C. 464, 480 (1987); sec.
1.183-2(b), Income Tax Regs. Not all factors are applicable in
every case, and no one factor is controlling. Abramson v.
Commissioner, 86 T.C. 360, 371 (1986); Allen v. Commissioner, 72
T.C. 28, 34 (1979); sec. 1.183-2(b), Income Tax Regs.
Manner in Which Activity Conducted
The fact that a taxpayer carries on the activity in a
businesslike manner and maintains complete and accurate books and
records may indicate that the activity was engaged in for profit.
Sec. 1.183-2(b)(1), Income Tax Regs. We find that petitioner was
very serious about her Appaloosa breeding and selling activity
and conducted it in a businesslike manner. She maintained
detailed records of her expenses which she relied upon in making
business decisions. She maintained a separate bank account for
her Appaloosa breeding and selling activity and did not commingle
the proceeds of the activity with her personal funds, with the
exception of one admitted instance for which she adequately
accounted. We find that petitioner had a business plan, which
was to breed horses for sale to young and nonprofessional adult
riders. In addition, we find that she continuously modified her
business plan to contain costs and to give herself every
opportunity to make a profit. We find that this factor favors
petitioner.
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