- 28 - profit motive. See Sullivan v. Commissioner, T.C. Memo. 1998-367 (generally no profit motive where lack of evidence that taxpayer used records to improve losing venture), affd. without published opinion 202 F.3d 264 (5th Cir. 1999). Petitioners also failed to prepare any financial statements, profit and loss projections, budgets, breakeven analyses, or marketing surveys, all of which can be significant financial tools to aid in “cutting expenses, increasing profits, and evaluating the overall performance of the operation.” Golanty v. Commissioner, supra at 430. We conclude that petitioners’ maintenance of books and records was simply to memorialize for tax purposes the various expenses associated with the activity. That petitioners were able to substantiate their claimed expenses simply does not prove that their books and records were kept or used in a businesslike manner. b. Petitioners’ Involvement in Other Profitable Enterprises There is no evidence in the record that shows how petitioners operated or participated in other profitable enterprises, such as Mr. McKeever’s employer, Aero Industrial Alloy. Thus, we are unable to consider whether the horse activity was operated in a similar manner. See sec. 1.183-2(b), Income Tax Regs.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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