-21- equipment and spend most of the next 3 years learning how to use the new equipment. His gross receipts plummeted; his losses increased even more. Supra tables 5 and 6. The parties have stipulated that petitioner did not have a written business plan, forecasting income, expenses, and net profit or loss, during the years in issue, and had not prepared any such written business plan before starting his videotape activity. When asked about this at trial, petitioner responded as follows: Q [Ms. DeCaro] Why did you not prepare a business plan? A [Petitioner] Well, I have my business plan in my head and that’s one of my businesses that I was doing when I was actually consulting was preparing business plans, and it seemed like a silly waste of paper to put it down in black and white. Petitioner did not present us with an oral description of the business plan that was in his head. Petitioner noted at trial that his father had continued to operate his own business until dying at age 92. When questioned on cross-examination, petitioner did not give any indication as to how long he thought it would take for him to earn enough income from his videotape activity to recoup the $155,000 or so that he had spent on equipment. The parties have stipulated that petitioner did not spend any money on advertising from 1993 through 1995; he relied solely on “word-of-mouth”. Petitioner’s Schedules C also show that hePage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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