- 13 - taxpayer conducted the activity for profit. Engdahl v. Commissioner, 72 T.C. 659, 666-667 (1979); sec. 1.183-2(b)(1), Income Tax Regs. Petitioner did not maintain accurate and complete books and records for M&S. Petitioner testified that it was not his practice to use bills of sale or purchase agreements when horses changed ownership. The documents that petitioner provided as bills of sale were computer-generated, and petitioner admitted to printing them from his computer hard drive in preparation for trial. Petitioner testified that it was not the general practice in the industry to provide bills of sale and that the important documents were the registration document and transfer report. At the time of trial, however, petitioner was unable to provide registration documents for any horse that he owned, and he did not have copies of transfer reports for any horses that he purchased or sold during the years in issue. Petitioner did not maintain records of the breeding of any mares. The materials that petitioner provided as evidence of his advertising were also computer-generated and were printed in preparation for trial. Petitioner provided no evidence of original advertisements used by M&S. Petitioner had no record of correspondence from other persons. The correspondence he provided was also computer-generated and was prepared for trial.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011