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Borissa has produced only two surviving horses, Bogaz and
Censuous. Despite the many breeding problems, petitioner
testified that she considered Borissa to be her best breeding
mare.
Petitioner also testified that she intends to offer services
to third parties, including training, coaching, and boarding.
Yet since 1988, petitioner has offered no such services. In
addition, the zoning restrictions at Falling Water Way and
Gavilan Hills prohibit petitioner from operating boarding or
livery stables on the properties. Petitioner has pointed to
nothing else from which she intends to derive a profit. On the
basis of these facts, we find that petitioner does not have a
plausible strategy for earning a profit.
Petitioner has introduced no evidence that she operated her
horse activity in a manner similar to that of profitable horse-
breeding businesses. None of the generally relevant indicators
described above could lead us to conclude that petitioner
operates her horse activity in a manner consistent with a
profitable venture of any type. This subfactor weighs heavily in
favor of respondent’s position.
c. Changes To Improve Profitability
When a taxpayer changes operating methods, adopts new
techniques, or abandons unprofitable methods in a manner
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