Ralph E. Wesinger, Jr. and Catherine R. Wesinger - Page 19




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          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.                              








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