- 25 - 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: March 27, 2008