Dennis L. and Margaret J. Knudsen - Page 26




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         Commissioner, 809 F.2d at 359.  For a taxpayer’s books and                   
         records to indicate a profit motive, the books and records should            
         enable a taxpayer to cut expenses, increase profits, and evaluate            
         the overall performance of the operation.  See Abbene v.                     
         Commissioner, T.C. Memo. 1998-330.                                           
              Although petitioners kept extensive financial records, they             
         were not used to review and reduce expenses or to enhance the                
         possibility of generating income.  For example, Mrs. Knudsen                 
         testified that a decision regarding termination of a breeding                
         line was made by considering whether an animal was producing                 
         young and taking care of them.  Petitioners did not introduce any            
         evidence that they used their financial and breeding records to              
         determine whether a specific breed was profitable.  Further,                 
         petitioners did not maintain records of revenues and expenses                
         associated with each animal or breed.  See, e.g., Steele v.                  
         Commissioner, T.C. Memo. 1983-63 (failure to keep track of                   
         expenses for each animal implies lack of profit motive).  Because            
         petitioners failed to use the existing books and records to                  
         minimize their expenses or otherwise foster profitability, the               
         fact that they maintained records does not indicate that the                 
         activity was carried on with a profit motive.  See Sullivan v.               
         Commissioner, T.C. Memo. 1998-367 (maintenance of records                    
         generally not indicative of profit motive where evidence did not             








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