- 12 - opinion 647 F.2d 170 (9th Cir. 1981). Based on all of the facts and circumstances in the present case, we hold that petitioner has failed to prove that she engaged in the horse breeding activity for profit within the meaning of section 183. See Rule 142(a); INDOPCO, Inc. v. Commissioner, supra; Welch v. Helvering, supra. We do not analyze in depth all nine of the factors enumerated in the regulation but rather focus on some of the more important ones that inform our decision. The fact that a taxpayer carries on the activity in a businesslike manner and maintains complete and accurate books and records may indicate a profit objective. Sec. 1.183-2(b)(1), Income Tax Regs. However, petitioner failed to develop a budget or a formal or informal business plan to determine whether the horse breeding activity could be operated profitably. Other than canceled checks and a few receipts, petitioner also failed to keep any books and records with respect to the horse breeding activity. Petitioner did not keep the type of records that could be used to increase the profitability of a business. Petitioner never prepared budgets or market projections that would outline strategies for ensuring a profitable business venture and making informed business decisions on a periodic basis. Such lack of information upon which to make educated business decisions tends to belie a taxpayer’s contentions that an activity was pursuedPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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