- 15 -
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
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: May 25, 2011