- 11 - 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 informationPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: November 10, 2007