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and the considerable volume of documentation that served to
substantiate the claimed expenses, as well as the pedigrees that
were kept for their horses. Finally, petitioners refer us to the
testimony of their current accountant, Mr. Hurley, to demonstrate
that their records during the years at issue were adequate and
consistent with a profit motive.
Although petitioners’ records were voluminous, the record
demonstrates that petitioners’ record keeping was nothing more
than a conscious attention to detail. See Golanty v.
Commissioner, 72 T.C. at 430. The records were not used to
review and reduce expenses or to enhance the possibility of
generating income. For example, Mrs. McKeever testified that
there were no written records that provided per-horse information
regarding the cost to maintain the horse but that such
information existed in her mind such that she could approximate
the cost to maintain a horse. She failed to demonstrate,
however, that she actually possessed such information, or that
she used it in an effort to achieve an economic profit from the
horse activity. See, e.g., Steele v. Commissioner, supra
(failure to keep track of expenses on a per-animal basis implies
lack of profit motive). Because petitioners failed to use the
existing books and records to minimize their expenses or
otherwise foster profitability, the fact that they maintained
records does not indicate that the activity was carried on with a
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