Ralph E. Wesinger, Jr. and Catherine R. Wesinger - Page 16




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          detail, keeping only the minimum records necessary to prepare tax           
          returns, was considered by the Court to be an indication that the           
          activity was not carried on for profit.  See id.                            
               Moreover, even in Golanty v. Commissioner, 72 T.C. at 430,             
          where the taxpayer kept a separate ledger on a monthly basis for            
          her horse-breeding enterprise, the Court stated that “there has             
          been no showing that books and records were kept for the purpose            
          of cutting expenses, increasing profits, and evaluating the                 
          overall performance of the operation.”  The Court labeled these             
          records merely “the trappings of a business” because the taxpayer           
          “failed to show that she used them to improve the operation of              
          the enterprise.”  Id.                                                       
               Petitioner here, like the taxpayers in Burger, Dodge, and              
          Golanty, appears to have kept the minimum records necessary to              
          prepare his tax returns.  As indicated above, simply maintaining            
          lists or files of expenses and receipts, without any further cost           
          accounting or analysis, carries little weight in establishing a             
          profit objective.                                                           
               Second, as regards similarity with comparable businesses,              
          neither petitioner nor respondent has offered any evidence as to            
          how profitable cattle ranches are run.  However, it seems                   
          unlikely that entrepreneurs seriously intending to profit from a            










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