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647 F.2d 170 (9th Cir. 1981). Greater weight is given to
objective facts than to a taxpayer’s mere statement of intent.
Dreicer v. Commissioner, supra at 645.
We consider each of these factors in turn.
Manner in Which Petitioner Carried On Her Horse Activity
The regulations under section 183 provide that carrying on
an activity in a businesslike manner indicates a profit
objective. Sec. 1.183-2(b)(1), Income Tax Regs. The regulations
explain that businesslike operations typically would involve the
maintenance of complete and accurate books and records, the
conduct of the activity in a manner similar to profitable
businesses of the same nature, and changes to improve operations
and profitability. See id. Numerous court opinions mention that
a businesslike operation often would involve a business plan.
See, e.g., Wesinger v. Commissioner, T.C. Memo. 1999-372.
With respect to books and records, we have held that the
maintenance of mere lists of and receipts for expenses without
any further cost accounting or analysis would not reflect good
business practices. See Wesinger v. Commissioner, supra; Dodge
v. Commissioner, T.C. Memo. 1998-89, affd. without published
opinion 188 F.3d 507 (6th Cir. 1999); Burger v. Commissioner,
T.C. Memo. 1985-523, affd. 809 F.2d 355 (7th Cir. 1987).
The term “businesslike manner” contemplates the use of cost
accounting techniques that provide the taxpayer with information
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