- 27 - moved his equipment to Colorado and began another mining operation, which he also quickly terminated when he discovered he had been misled. In 1996, following the loss of the Quartette Mine project, petitioner began to investigate the sale of decorative rock as an income source and opened a rock yard in Las Vegas. Petitioner took out an advertisement in the telephone directory yellow pages with respect to his decorative rock business. Petitioner’s revenue from the sale of decorative rock in the 3 years prior to trial was significant, growing steadily from year to year; i.e., $32,364 in 1997, $126,170 in 1998, and $373,566 in 1999. Petitioner continually searched for operating methods and business ventures to reduce his losses, generate revenue, and improve profitability. Ultimately, petitioner was successful in generating substantial revenue from the sale of decorative rock. Thus, we are convinced that the changes petitioner implemented before, during, and after the years at issue have the potential to affect the long-range profitability of petitioner’s mining activity materially and favorably. See Golanty v. Commissioner, 72 T.C. at 428 (changes must be sufficient to change materially the prospect of profitability). d. Summary Petitioner’s changes in operating methods, adoption of new techniques, and abandonment of unprofitable methods to improvePage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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