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Oklahoma. According to petitioner, the farm was owned and
operated by his parents for many years. Upon his father's death,
the farm passed to his mother, who with petitioner's help
continued to farm the property until her death in 1982.
Petitioner claims that he operated the farm after the death of
his mother. He now claims to be the owner of the property,
although for reasons unexplained, the property is still titled in
his mother's name. According to petitioner, he traveled to the
farm from his residence in Florida several times a year in order
to plant and harvest crops.
During the years in issue, there were several structures on
the farm property, including barns and a farm house. The house
was uninhabitable, and petitioner stayed in a local motel when he
traveled to the farm from his residence. There were no
recreational facilities on the property, such as tennis courts or
swimming pools. According to petitioner, there were two crops
planted and harvested on the farm during the years in issue,
wheat and peanuts, although there is no corroborative evidence on
this point.
Petitioners filed Schedules F, Profit or Loss from Farming,
with their Federal income tax returns for the years 1991, 1992,
and 1993. Petitioners' returns for those years were prepared by
a certified public accountant. On the Schedules F, petitioner
reported farm income in the respective amounts of $960, $1,215,
and $1,100. Petitioner also claimed farm expense deductions
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