Richard J. and Melodie D. McKeever - Page 30




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            their mares and sometimes used top-ranked stallions, their                                 
            efforts to market their horses were unfocused and anemic prior to                          
            and during the years at issue.  Petitioners did not sell any                               
            horses during the years at issue, and the only sales that have                             
            occurred through June 1998 have been culling sales.  None of the                           
            changes made during the years at issue, including petitioners’                             
            reliance on Dr. Cortelezzi, had any material impact on                                     
            profitability.                                                                             
                  Petitioners’ marketing and sales efforts have changed                                
            little since the inception of the enterprise.  Relatively little                           
            has been spent on advertising.  Cf. Burrow v. Commissioner, T.C.                           
            Memo. 1990-621.  Petitioners advertised their operation and the                            
            availability of their horses in trade magazines, journals, and                             
            via local horse show sponsorships and parades.  Petitioners also                           
            showed, on average, two or three of their horses each year at                              
            regional events on the West Coast.  However, petitioners had no                            
            marketing plan; they did not even have business cards until 1993.                          
            Considering the importance of horse sales to their business plan,                          
            petitioners’ failure to attempt to reach a larger customer base                            
            is not consistent with the behavior of a profit-minded taxpayer.                           
            See Dodge v. Commissioner, T.C. Memo. 1998-89, affd. without                               
            published opinion 188 F.3d 507 (6th Cir. 1999).                                            










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