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After concessions,1 the sole issue for decision is whether
petitioner operated her farm with an actual and honest profit
objective in 1988, 1989, and 1990. We hold that she did not.
Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner lived in Oregon City, Oregon, when she filed her
petition. Petitioner's parents and grandparents were farmers.
Petitioner is experienced and knowledgeable about farming.
She learned how to handle farm animals and equipment and how to
ride and show horses competitively when she was a teenager. At
age 14, petitioner was designated to manage her family's farm
while her father served in World War II. Petitioner has lived on
a farm since 1949. Petitioner qualified and was nominated for
the American Olympic Equestrian Team in 1952.
Petitioner graduated from the University of Oregon in 1953.
She taught riding and philosophy in Pennsylvania from 1953 to
1955. Petitioner worked on a Montana cattle ranch during part
1 Petitioner conceded that she is not entitled to deduct
$5,475 for employee business expenses that she claimed on her
1988 return. Respondent conceded that petitioner is not liable
for additions to tax under sec. 6651 for 1989 and 1990 or under
sec. 6653(a) for 1988.
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