- 16 - Sugar Tree, and of their efforts to reduce hay and other costs, dispositive on the issue of their profit motive. It is beyond this Court’s purview to second-guess petitioners’ business judgment or the manner of operations of their business. We decline to do so. In this case, we are presented with taxpayers who admit that during 1999, they became aware that they could not make a profit but yet still continued business operations while taking steps to mitigate their expenses until the business and property could be sold. Accordingly, we now address whether petitioners’ admission at trial should trump the other facts and circumstances of this case. While we cannot disregard Mr. Rozzano’s admission that at some point in 1999 he realized that his hopes of turning the boarding activities into a profitable business were unattainable we do not find that as of that moment, petitioners’ activities ceased to be a bona fide business within the meaning of section 183. Moreover, our decision comports with this Court’s holding in Dreicer, where greater weight must be afforded to the consideration of all of the facts and circumstances. In this case, the facts and circumstances surrounding petitioners’ actions between the time of their realization with respect to profitability in 1999 and the ultimate disposal of the propertyPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: November 10, 2007