- 31 - were in California. Petitioner presented no evidence that she was aware of the state of the market or other factors that may affect profitability. “While a formal market study is not required, a basic investigation of the factors that would affect profit is.” Burger v. Commissioner, supra; see also Golanty v. Commissioner, supra at 432; Wesinger v. Commissioner, T.C. Memo. 1999-372. Petitioner testified that she discussed aspects of her horse activity with two C.P.A.s, Ms. Pope and Mr. Wessman, which their testimony corroborated. However, it is unclear whether they discussed anything more than petitioner’s expenses in preparing the annual profit and loss statements and Schedules C. While Ms. Pope and Mr. Wessman may have expertise in accounting, neither testified to having experience in running a profitable horse- breeding business. Since 1988, petitioner has not consulted with experts regarding the economic aspects of running a profitable horse-breeding business. Considering petitioner’s long history of losses, this is not indicative of a profit motive. See Golanty v. Commissioner, supra at 432; Wesinger v. Commissioner, supra; Hillman v. Commissioner, T.C. Memo. 1999-255; Dodge v. Commissioner, T.C. Memo. 1998-89. None of petitioner’s reference materials and publications were devoted to the business aspects of horse breeding. Petitioner testified that only one of the references in herPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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