Dennis L. and Margaret J. Knudsen - Page 28




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         petitioners claim that they eliminated unprofitable breeding                 
         groups and expanded profitable breeding groups.  Second,                     
         petitioners contend that they minimized the expenses of ERE by               
         performing necessary duties themselves.  For example, Mrs.                   
         Knudsen learned to perform microchip implantation, and Dr.                   
         Knudsen landscaped the property and attended to the animals’                 
         health needs.  Finally, petitioners argue that they decreased                
         expenses by rotating the grazing pastures to reduce the amount of            
         hay purchased, by purchasing animals that could be housed in the             
         existing facilities, and by purchasing feed in bulk.                         
              Petitioners have not convinced us that the changes had a                
         material impact on ERE’s profitability.  See Golanty v.                      
         Commissioner, supra at 428 (changes must be sufficient to alter              
         materially the prospects of making a profit).  The amounts of                
         petitioners’ losses did not decline despite petitioners’ claims              
         that they cut costs and eliminated unprofitable breeding groups.             
         Petitioners’ greatest losses were during 2000 and 2001, more than            
         10 years after starting their breeding activity.  Further,                   
         petitioners did not expand or eliminate any breeding lines using             
         an economic analysis of the individual breeds.                               
              Finally, we note that petitioners’ marketing and sales                  
         efforts have changed little since the inception of the activity.             
         Relatively little has been spent on advertising.  Cf. Burrow v.              
         Commissioner, T.C. Memo. 1990-621.  In fact, petitioners incurred            







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