- 10 -
and from Long Beach. Business licenses and advertising expenses
seem to be the only expenses that we can definitively identify as
directly related to the nursery activity.
Under these circumstances, petitioners have failed to
establish an actual and honest objective of making a profit from
the nursery activity. We do not have an accurate financial
picture of that activity. In litigating this case, petitioners
chose this all-or-nothing approach, and they have the burden of
establishing that respondent's determinations were incorrect.
Rule 142(a). Petitioners have not carried that burden.
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011