- 15 - be a wholly fortuitous result.” Id. Given this standard, the Court in Burger found the taxpayers’ annual posting to a ledger from bills and receipts accumulated throughout the year, under headings for revenues and expenses, to be insufficient. See id. The Court declared the ledger inadequate for any meaningful cost analysis, in part because it failed to allocate costs and overhead among the animals of the taxpayers’ dog-breeding operations. See id. As a result of this failure, the taxpayers’ records did not provide enough information for even determining what the break-even point might be for dog sale purposes. See id. The annual posting was also fatal to the taxpayers’ contentions because it precluded frequent monitoring of costs and profitability. See id. Similar focus on maintaining records useful in making business decisions is found in Dodge v. Commissioner, T.C. Memo. 1998-89, affd. without published opinion 188 F.3d 507 (6th Cir. 1999). In that case the taxpayers kept invoices and receipts for their horse-breeding business and maintained an itemized list of expenses. See id. Nonetheless, the Court noted that “petitioners did not prepare any business or profit plans, profit or loss statements, balance sheets, or financial break-even analyses for their horse-breeding activity.” Id. This lack ofPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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