Nora E. Keating and Richard L. Shearer - Page 12




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          required to make informed business decisions.   Burger v.                   
          Commissioner, supra.  The purpose of maintaining business books             
          and records is more than to “memorialize for tax purposes the               
          existence of the subject transactions” and includes providing a             
          “means of periodically determining profitability and analyzing              
          expenses”.  Id.; see also Dodge v. Commissioner, supra (minimal             
          records used to prepare tax returns not adequate to support a               
          finding that activity was carried on for profit).  The mere                 
          ability to substantiate expenses does not establish that the                
          records were kept in a businesslike manner.                                 
               In the context of animal-breeding activities, we have                  
          indicated that the absence of detailed monthly expense records              
          for each animal may indicate a lack of profit objective.  See               
          McKeever v. Commissioner, T.C. Memo. 2000-288; Dodge v.                     
          Commissioner, supra.                                                        
               Petitioner failed to keep track of expenses on a per-horse             
          basis and failed to prepare any financial projections which would           
          have aided her in evaluating the economic performance of her                
          horse activity.  The financial records maintained by petitioner             
          appear to have been maintained primarily for tax purposes.                  
               Petitioner emphasizes that she maintained detailed records             
          for each horse relating to vaccinations, training, and ovulatory            
          cycles.  The maintenance of these types of records, however, is             
          as consistent with a hobby as with a business.  See Golanty v.              







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