Richard J. and Melodie D. McKeever - Page 25




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            intent to improve profitability.  See Engdahl v. Commissioner, 72                          
            T.C. 659, 666-667 (1979); sec. 1.183-2(b)(1), Income Tax Regs.                             
                  Petitioners contend that they operated their horse activity                          
            in a businesslike manner because they maintained accurate books                            
            and records, persevered in their sales and marketing efforts,                              
            culled their herd and focused on the highly marketable registered                          
            paso fino breed, and changed operating methods.                                            
                  Respondent asserts that the books and records served no                              
            part in controlling costs and increasing profitability, that                               
            anemic and ineffective sales and marketing efforts do not support                          
            a profit motive, that petitioners continued to breed horses from                           
            the bloodline allegedly culled, and that the changes in operating                          
            methods were insufficient to materially affect the activity’s                              
            profitability.  Respondent also asserts that petitioners used                              
            poor business practices in carrying on the activity.                                       
                        a.  Petitioners’ Record Keeping                                                
                  Petitioners maintained copies of invoices and checks which                           
            documented horse-activity expenses and which were used to prepare                          
            an expense journal at the close of each taxable year.  The                                 
            maintenance of these limited records, however, represents nothing                          
            more than petitioners’ substantiation of the expenses claimed on                           
            their returns.  As we have stated previously:                                              
                  The purpose of maintaining books and records is more                                 
                  than to memorialize for tax purposes the existence of                                





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