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horses, did it include specific business advice on how to start
and operate a horse breeding business profitably, did she follow
the advice? Nor is there credible evidence in the record that
any of these purported experts were actually experts on anything
related to the conduct of the business of breeding and showing
horses (or even on the conduct of a business in general). While
petitioner did testify generally that her daughter is a certified
public accountant, we know nothing else about her daughter’s
practice of public accounting (e.g., what is her specialty) or,
more specifically, whether she is an expert on the subject of
horse breeding and showing. We also note as to this daughter
that each of petitioner’s 1988 through 2002 tax returns appears
to have been prepared by someone else.
Of course, petitioner has over the years acquired some sort
of hands-on experience on the subject of horse breeding from the
point of view of a horse breeder. The record, however, does not
reflect that she has ever acquired any knowledge of the business
or economic aspects of horse breeding so as to be prepared for
the economic realities of a horse breeding and showing business.
We find nothing credible to suggest that she prepared for the
economic aspects of the activity by study or consultation with
experts, nor has she shown that, before starting the activity,
she had any idea of what her ultimate costs might be, how she
might achieve any degree of cost efficiency, the amount of
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