Dennis L. and Margaret J. Knudsen v. Commissioner of Internal Revenue, <sup Id="fnr_fnote1"><a Href="fn_fnote1"…

Summary

The Tax Court denied petitioners' motion for reconsideration of its prior determination that their animal-breeding activity was not operated for profit. The Court held that it was not required to decide whether the burden of proof shifted under section 7491(a) because the evidence preponderated in the Commissioner's favor, making the allocation immaterial. The Court also declined to consider petitioners' newly raised argument that each regulatory profit-factor was a separate factual issue for burden-shifting purposes.