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T.C. 132 (1992); Cannon v. Commissioner, 949 F.2d 345, 352 (10th
Cir. 1991), affg. T.C. Memo. 1990-148; sec. 1.183-2(a), Income
Tax Regs.
Where a taxpayer carries on an activity in a businesslike
manner and maintains complete and accurate books and records,
where the activity is conducted in a manner substantially similar
to that of other comparable businesses that are profitable, and
where changes are made to the activity’s operating method if
necessary to improve profitability, such circumstances indicate
that the activity is engaged in for profit. See sec. 1.183-
2(b)(1), Income Tax Regs. Similarly, a taxpayer’s business plan
may tend to show businesslike operations. See Sanders v.
Commissioner, T.C. Memo. 1999-208.
The only record of Omega’s activity viewed by the Court was
a summary containing a review of the farm receipts and
expenditures. The summary, however, did not provide the kind of
detailed and relevant information that could be used by
petitioners or the Court for evaluating the farm activity’s
profitability, such as: A detailed listing of farm expenses; the
number and types of animals bought and sold by petitioners; the
number of animals on the property that produced pasture rent; the
specific items of farm equipment that were depreciated; and the
specific items that were repaired and maintained. Omega
maintained only one bank account for both the farm activity and
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