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accurate books and records, whether the activity was conducted in
a manner substantially similar to comparable businesses that are
profitable, and whether changes were attempted in order to
improve profitability. Engdahl v. Commissioner, 72 T.C. 659,
666-667 (1979).
Petitioners assert that they have maintained records for
their activities. However, their books of account for the apple
orchard consist of their bank deposit slips, check stubs, and tax
forms. Petitioners have two bank accounts, one in the name of
petitioner and the other in the name of Twin Creeks Farm.
Petitioner testified that when he received money, from whatever
source, he deposited it in whichever account needed the money.
He further testified that he used both accounts as family
accounts.
Petitioners did not present any production records for the
apple orchard. In fact, at trial petitioner was not even certain
of the exact number of trees in the orchard. Thus, we find that
petitioners kept no separate complete and accurate books or
production records for the orchard activity.
Although petitioners' tax preparer, Susan Bladorn-Dukes,
testified that petitioners' canceled-checks method of recording
income and expenses was much like that of other farmers for whom
she prepares tax returns, she also testified that most of those
farms were "absolutely not" self-supporting. Thus, we do not
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