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accompanied petitioner on weekend visits. (Petitioners failed to
maintain mileage logs for their trips to the Corona property.)
While at the Corona property, petitioner often assisted in the
harvesting and packing of the macadamia nuts and persimmon fruit.
Petitioners grouped their tree-farming activities (i.e., their
macadamia nut and persimmon fruit operations, which they called
“Rojo International”) as a single Schedule C activity. The tree-
farming activities never generated a profit. The following chart
sets forth the revenues and expenses from petitioners’ tree-farming
activities between 1992 and 1996:
Year Revenue Expenses
1992 $440 $55,053
1993 490 61,280
1994 0 57,578
1995 1,900 68,336
1996 1,400 88,075
The record does not reveal the revenue and expenses from
petitioners’ tree-farming activities prior to 1992.
Rental Activity
Beginning in the early 1980’s, petitioners were employed (on
a part-time basis) as teacher/trainers for the Christian Reform
Church (the church). Frequently, petitioners allowed church
members to use the Corona property for religious retreats.
Petitioners maintained six trailers on the Corona property. During
the religious retreats, church members were housed in petitioners’
trailers, for which petitioners received a nominal rental fee.
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Last modified: May 25, 2011