- 13 - "The purpose of maintaining books and records is more than to memorialize for tax purposes the existence of the subject transactions; it is to facilitate a means of periodically determining profitability and analyzing expenses such that proper cost saving measures might be implemented in a timely and efficient manner. * * *" [Citations omitted.] See also Steele v. Commissioner, T.C. Memo. 1983-63 (checks served as adequate substantiation for claimed expenses but were not businesslike records). This factor favors respondent. Preparation for the activity by extensive study of its accepted business, economic, and scientific practices or consultation with people who are expert in these practices may indicate a profit objective where the taxpayer carries on the activity in accordance with such practices. Sec. 1.183-2(b)(2), Income Tax Regs. Petitioner had personal experience that enabled him to conduct his gold mining activity. He knew dredging from his primary job as a deck engineer and hydraulic equipment operator. He was a certified scuba diver. He was skilled in the use of dredging equipment. He studied mining literature and attended a few meetings with others interested in gold mining. He gained gold dredging experience from years of prospecting prior to 1994. However, petitioner did not consult with experts in the manner designed to establish how such an activity could be conducted profitably. Petitioner’s gold mining efforts,Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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