- 10 - ranchers experience a history of operating losses as money is spent improving their land but will make a profit when they eventually sell their ranches. Petitioner stated that the value of his ranch has appreciated significantly, and he estimated that the value of his ranch has increased from $150 per acre to approximately $1,000 to $1,500 per acre. Without supporting documentation, petitioner’s testimony is self-serving, and it is well established that this Court is not bound to accept at face value such unverified testimony from a taxpayer. See Shea v. Commissioner, 112 T.C. 183, 189 (1999); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). We apply the nine factors provided in the regulations, sec. 1.183-2(b), Income Tax Regs., to the limited evidence petitioner introduced to prove that he was engaged in his horse activity for profit. In the complete absence of books and records, we can only conclude that petitioner did not engage in his horse activity in a businesslike manner. Although petitioner claims that he sent receipts to his accountant twice a year for purposes of maintaining books and records for his ranch, petitioner did not introduce these books and records into evidence. In addition, petitioner did not develop a budget or an informal business plan to project whether the horse activity could be operated profitably, did not have a separate bank account for his horsePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011