George W. and Margaret L. Gagnon - Page 10

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          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.                          


























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