- 17 - A. Manner in Which the Activity Is Conducted Petitioners hired professionals to keep books and records and to prepare their returns. They also hired professionals to work in the horse activity as grooms, braiders, horseshoers, and veterinarian. While these facts weigh in petitioners favor, they are not the only facts presented to the Court. While petitioners did keep records, they did not have bills of sale for all their horses, and the records appear to be faulty. Dr. Prieto could not explain why the show costs and entry fees were so low for 1996. Mrs. Prieto testified that they understated the horse activity’s show costs for 1996. We agree.6 Even though they had records reporting substantial losses, petitioners never developed a written business plan or made a budget. Dr. and Mrs. Prieto testified that the “business plan” of the horse activity was to buy, train (develop), show, and sell horses. This is not a plan; this is merely a statement of what the horse activity did. While petitioners wrote out “business goals” for 1994 and 1995, they never developed a plan to achieve these goals. Petitioners claimed to have hired other riders, such as Annalee Bennet, to show the horses. The horse show entry forms for 1994 and 1995 list only petitioners’ daughters and Nicole as 6 We note that the likely effect of this understatement was to create the appearance of a profit for the horse activity for 1996 when none in fact existed.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011