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cutting horse competitions and claims to have been one of the top
nonprofessionals.
Petitioner’s Plan
Petitioner had no written business plan for the Schedule F
activity. Petitioner intended to buy quarter horses, train them
to be cutting horses, show them, establish their reputations, and
sell them. He intended to devote more time to the Schedule F
activity following his retirement from Wal-Mart.
Record Keeping
During the years at issue, petitioner prepared neither
profit and loss statements nor written projections of income or
loss for the Schedule F activity. He maintained no records of
the expenses associated with, or the winnings on account of,
particular horses. Petitioner maintained a separate checking
account for the Schedule F activity. Nevertheless, petitioners
often wrote checks on their personal account with respect to the
Schedule F activity. Petitioner wife received the bank
statements with respect to the Schedule F activity checking
account. She did not always open those statements, nor did she
always reconcile the statements with the check book.
Advertising
Prior to and during the years in issue, petitioner did no
advertising with respect to the Schedule F activity. The horses
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Last modified: May 25, 2011