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her Federal income tax returns for those respective years, she
reported that she had paid $1,518 and $1,645 of “training”
expenses during those years. Sixth, she testified in one setting
that she currently owns three horses; she then testified in
another setting that she currently owns four horses. She also
first testified that she keeps breeding papers on most of her
horses, but then, in reply to a question asked three questions
later, testified that she keeps breeding papers on all of her
horses. Seventh, she repeatedly referred to incorrect dates, and
she specifically acknowledged during her testimony that her
memory is poor.
We now turn to the nine enumerated factors and discuss them
seriatim.
1. Manner in Which the Activity Is Conducted
The fact that a taxpayer carries on an activity in a
businesslike manner may indicate that the activity is engaged in
for profit. Sec. 1.183-2(b)(1), Income Tax Regs. Subfactors to
consider in deciding whether a taxpayer has conducted an activity
in a businesslike manner include (1) whether the taxpayer
maintained complete and accurate books and records for the
activity, (2) whether the taxpayer conducted the activity in a
manner substantially similar to those of other comparable
activities that were profitable, and (3) whether the taxpayer
changed operating procedures, adopted new techniques, or
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