- 28 - 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 incurredPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 NextLast modified: March 27, 2008