Dennis L. and Margaret J. Knudsen - Page 25




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                        a.  Petitioners’ Record Keeping                               
              Petitioners’ bookkeeper maintained books and records for ERE            
         using Quickbooks software.  The software produced financial                  
         reports, including a general ledger.  Petitioners kept ERE’s                 
         records separate from Dr. Knudsen’s medical practice records and             
         petitioners’ personal records.  Petitioners also maintained a                
         separate bank account for ERE.                                               
              Although we are satisfied that petitioners kept financial               
         records of their breeding activity, we are not convinced that                
         petitioners’ record keeping represented anything other than an               
         effort to substantiate expenses claimed on their return.  As we              
         have held:                                                                   
                   The purpose of maintaining books and records is                    
              more than to memorialize for tax purposes the existence                 
              of the subject transactions; it is to facilitate a                      
              means of periodically determining profitability and                     
              analyzing expenses such that proper cost saving                         
              measures might be implemented in a timely and efficient                 
              manner.  * * *  [Burger v. Commissioner, T.C. Memo.                     
              1985-523 (citing Golanty v. Commissioner, 72 T.C. 411,                  
              430 (1979), affd. without published opinion 647 F.2d                    
              170 (9th Cir. 1981)), affd. 809 F.2d 355 (7th Cir.                      
              1987).]                                                                 
         Petitioners presented no evidence that their books and records               
         were used to review profitability or to implement cost-saving                
         measures.                                                                    
              While a taxpayer need not maintain a sophisticated cost                 
         accounting system, the taxpayer should keep records that enable              
         the taxpayer to make informed business decisions.  See Burger v.             







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