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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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