Anderson College Of Business

Why do you Want a Graduate Degree in Business? You’re a flourishing businessperson who views an MBA as the best industry credential. Maybe your wish is to start your own business or create a legacy as part of a well-known business institution. You make an effort to create long-term value and distributed success for customers, employees and your community. As a busy professional, you need a degree that can propel your career and provide utmost flexibility simultaneously, as well as one which represents your beliefs.

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Since she started La Brisa Farm, Mrs. Jary-Mathis has frequently talked about training and mating strategies with prominent statistics in the cutting horse industry. She continuously works online research to identify the best horses in the country, and she’s attended workshops to find out more about the cutting equine business. Mrs. Jary-Mathis has developed expertise in breeding quality slicing horses, but she lacks business experience.

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Mrs. Jary-Mathis went to a workshop on ranching for revenue, but that will not make her a specialist. Moreover, she went to the seminar long after she began the experience. Petitioners’ failure at the outset to seek advice from experts on the financial areas of owning a cutting horse farm indicates that they lacked a profit motive.

See Burger v. Commissioner, 809 F.2d 355, 359 (7th Cir. T.C. Memo. 1985-523; Smith v. Commissioner, T.C. Memo. 1997-503, aff’d without released opinion, 182 F.3d 927 (9th Cir. Mrs. Jary-Mathis devotes considerable time and work to La Brisa Farm. She typically spends 40 hours a week on the cutting horse activity and 60 hours a week through the top cutting events.

Although Mrs. Jary-Mathis works hard, her work consists of significant recreational and personal aspects. She works together with cutting horses, which have been her passion since she was young. She spends time with her girl at horse shows, and she derives a sense of personal satisfaction from owning high-quality slicing horses. On balance, this factor weighs in petitioners’ favour, however the personal and recreational areas of the experience limit its influence on our overall analysis. An expectation that assets found in the experience will appreciate in value may indicate a profit motive even if the taxpayer derives no profit from current operations.

Sec. 1.183-2(b)(4), TAX Regs. Foster v. Commissioner, T.C. Memo. 2012-207; see Golanty v. Commissioner, 72 T.C. Mrs. Jary-Mathis testified that she actually is expected by her horses to appreciate in value as her broodmares produce successful foals. However, petitioners have failed to present proof that the appreciation shall recoup the gathered losses. 1,252,by December 31 500, 2008. Any understanding on petitioners’ horses only minimally offsets the large deficits petitioners have suffered since beginning their cutting horse activity. Petitioners also provided some evidence that the La Brisa Farm property has increased in value, but this will not indicate that that they had a profit motive for their slicing horse activity.