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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 of
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