Michael J. Rozzano, Jr., and Rose Marie Rozzano - Page 15




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          services during the years in which they were continuing the                 
          boarding activities while, at the same time, preparing the                  
          property for sale.                                                          
               Mr. Rozzano also testified that it was primarily the cost              
          associated with hay feed that caused their business to experience           
          ongoing losses.  We note that for 1999 and 2000, hay and feed               
          expenses accounted for 34 percent and 32 percent, respectively,             
          of all cash expenses before depreciation.  To this end,                     
          petitioners devised a strategy to ensure that their hay supply              
          costs could be mitigated so as to reduce losses and accord with             
          their budget projections.  Petitioners took steps to ensure that            
          the hay would remain dry and free from infestation and that their           
          helper would not waste it unnecessarily.  Petitioners also took             
          steps in 1999 and 2000 to reduce other operating expenses, such             
          as travel, meals, and utilities.  These costs did, in fact,                 
          decrease from 1999 to 2000.  Although petitioners did make                  
          efforts to reduce their hay expenses by protecting their supply,            
          an increase in the number of boarders in 2000, coupled with an              
          increase in the wholesale price of the feed, resulted in an                 
          increase in hay costs.  While we recognize that efforts to                  
          improve profitability can be indicative of whether petitioners              
          intended to realize a profit, we do not find their refusal to               
          raise stall rental prices or hire additional help, especially in            
          the light of their existing contracts, of their decision to sell            







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