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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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