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ranching venture would allow land allegedly purchased for that
purpose to sit unused for 6 years before first placing cattle on
the property.
Third, concerning attempts to improve profitability through
changes in methods and techniques, petitioner’s efforts in this
area for the years in issue can again only be termed minimal.
Fencing was installed in 1993. Two wells were added to the
property between 1994 and 1996. Sagebrush removal was begun in
late 1995. Yet, 1996 was the first year any cattle were grazed.
Spreading a small number of improvements over the 7-year period
of ranch land ownership, from 1990 to 1996, cannot overcome
petitioner’s failure to abandon more expeditiously the provenly
unprofitable technique of grazing no cattle.
Fourth, regarding a business plan, petitioner is correct in
asserting that lack of a formal, written business plan is not
determinative of lack of profit objective. See Sanders v.
Commissioner, T.C. Memo. 1999-208. Nonetheless, some indication
of “a plan for success (i.e., profitability)” should be given.
Id. Petitioner’s situation and “buy cows, feed cows, sell cows”
testimony here seem analogous to that in Sanders, where the Court
stated: “Given the substantial, but expected, costs associated
with the Schedule F activity, we need more than petitioner’s
representation that he could make money if he sold enough horses
at high enough prices to conclude that petitioner had a plan to
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