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the changes had or will have a material impact on her horse
activity’s profitability. See Golanty v. Commissioner, 72 T.C.
at 428 (changes must be sufficient to change materially the
prospect of profitability); McKeever v. Commissioner, T.C. Memo.
2000-288. Accordingly, this subfactor weighs in favor of
respondent’s position.
d. Other Considerations
Petitioner has a Falling Water Arabians business card.
However, this card was prepared in the late 1980s, and the phone
numbers are no longer correct. The existence of an out-of-date
business card does not weigh in favor of petitioner’s position.
Petitioner keeps extensive records of health, certification,
and pedigree, as well as promotional materials used in picking
stallions to breed Borissa to, and correspondence with other
parties regarding her horse activity. However, the keeping of
these records is as consistent with a hobby as with a business.
See Golanty v. Commissioner, supra at 430; Burger v.
Commissioner, T.C. Memo. 1985-523. The existence of these
records does not weigh in favor of petitioner’s position.
Petitioner argues that her decision to lease Borissa before
buying her evidences businesslike behavior. Petitioner
introduced no evidence that this is a common practice in
profitable horse-breeding businesses. This decision does not
weigh in favor of petitioner’s position.
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