- 10 - manner as other profit-making horse-breeding operations, made changes in their method of operations to increase profitability, and attempted to diversify their activities to make a profit. Petitioners’ situation is distinguishable from the taxpayers in Engdahl. Petitioners offered no evidence to show that their horse-breeding activity was unprofitable due to unexpected adverse market conditions. Nor did they show that the activity was similar to other profit-making horse-breeding operations. Petitioners did not make changes to their operation in an attempt to make it profitable.1 Indeed, Dr. Harrington testified that he was unwilling to expand the operation because it was not cost effective to do so. Finally, Dr. Harrington made no attempt to diversify the operation in order to earn a profit. Dr. Harrington’s continuation of the inherently money-losing operation belies petitioners’ contention that petitioners engaged in the activity to make a profit. 1Petitioners argued on brief that they made several changes to improve profitability. First they claim they “switched” to a “well-known Appaloosa Foundation bloodline”. In fact, the only stallion that they have ever used was Provoking. We do not understand what they mean by a “switch”. Second, they claim that they identified a special niche market of producing palomino Appaloosas and attempted to expand to meet market demand. In fact, petitioners did not attempt to expand and have not been able to sell their two best foals (calling into question the level of demand). Finally, petitioners point out that Dr. Harrington has developed farrier, veterinarian, training, and marketing skills. While he may have developed or improved his skills, these were not significant changes made to improve profitability and did not have the effect of improving profitability.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011