- 19 - See, e.g., Golanty v. Commissioner, 72 T.C. at 432; Sanders v. Commissioner, supra; Dodge v. Commissioner, supra; Underwood v. Commissioner, supra; Burger v. Commissioner, supra. For instance, in Golanty v. Commissioner, supra at 432, the Court recognized that the taxpayer was an intelligent person who had acquired a good deal of knowledge about horses and their breeding. Nonetheless, the Court emphasized that because the taxpayer “never consulted any books nor any person who gave her advice regarding the business side of the operation”, she “failed to show that she sought or acquired the expertise that would enable her to turn the horse-breeding operation into a profitable business.” Id. Similarly, the Court in Burger v. Commissioner, supra, first observed that the taxpayers there “read numerous books and periodicals pertaining to the breeding of dogs and consulted with individuals whom petitioners considered to be expert in the field”. Again however, the Court found these activities not indicative of a profit objective because the taxpayers undertook the venture “without consulting with any experts on the business end of the activity” and “with no concept of what their ultimate costs might be, how they might operate at the greatest cost efficiency, how much revenues they could expect, or what risks could impair the generation of revenues.” Id.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011