Joyce E. Hastings - Page 15




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          present in the submitted plan was also present in 1993 is false.            
          Even the beginning sections of the submitted business plan                  
          contain language that could not have been present in 1993.  For             
          example, on page three in a section entitled “SUMMARY OF                    
          SADDLEBRED INDUSTRY”, the submitted business plan references the            
          lineage of petitioner’s horse “Princess”.  Princess was not born            
          until 1994.  The Court is not convinced that any portion of this            
          submitted business plan was drafted before or during 1993.  It is           
          therefore doubtful that petitioner had any business plan in 1993.           
               Other than her claim to have drafted a business plan,                  
          petitioner does not claim to have made any changes during 1993              
          from the manner in which she maintained books and records for the           
          years at issue in Hastings v. Commissioner, T.C. Memo. 1999-167,            
          where we held that petitioner’s horse activity was not engaged in           
          for profit.                                                                 
               Petitioner’s attempts to improve profitability through                 
          changes in operating methods and techniques can only be termed              
          minimal.  While attempting to enter into a deal to breed one of             
          her horses with Andalusians, petitioner pastured Andalusians                
          owned by a third party, thus producing gross receipts of $9,774.            
          Compared to petitioner’s reported gross receipts of only $752               
          from horse activity for the years 1989 to 1992, these pasturing             
          receipts were substantial.  Despite this potential for income,              
          petitioner declined to continue pasturing horses after the                  






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