Mary Ann Tobin - Page 16




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          petitioner's various undertakings are not part of a single                  
          farming activity.  Raising crops and animals, leasing cropland,             
          and participating in a Government agricultural subsidy program              
          may be one activity if they are attempts by the farmer to                   
          generate income from the farm.  See, e.g., Hoyle v. Commissioner,           
          supra.                                                                      
               Respondent relies on Drummond v. Commissioner, T.C. Memo.              
          1997-71, affd. in part and revd. in part without published                  
          opinion 155 F.3d 558 (4th Cir. 1998), for the proposition that              
          two farm undertakings that are not conducted on the same land are           
          separate activities.  Respondent's reliance on Drummond v.                  
          Commissioner, supra, is misplaced.  In Drummond, we held that the           
          taxpayer's horse and cattle undertakings were separate activities           
          because we were not convinced that the taxpayer intended to use             
          his herd of cattle to manage the pasture for his horses.  In                
          contrast, petitioner operated the gardens and farm as one                   
          activity.                                                                   
               Respondent contends that Broadmoor Gardens and petitioner's            
          farm were separate activities because petitioner and Ms. Beard              
          operated the gardens as a joint venture.  Respondent also                   
          contends that the farm and Broadmoor Gardens did not depend on              
          the success of the other.  We disagree.  Respondent cites no                
          reason or authority to support the contentions that an                      
          undertaking may not be part of an activity just because it is               






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