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out of 37 years. Petitioner has not shown that she in fact ever
considered whether land appreciation would more than offset her
losses, much less that it did so.
This factor favors respondent.
8. Financial Status of Taxpayer
Substantial income from sources other than the activity,
especially if the losses generate substantial tax benefits, may
indicate that the taxpayer is not conducting the activity for
profit. Sec. 1.183-2(b)(8), Income Tax Regs.
Petitioner contends that, because she is not wealthy, her
purpose in having a farm was not to offset substantial income
from other sources. We disagree. While petitioner is not
wealthy, her farm losses enabled her to avoid paying Federal
income taxes from 1985 to 1993. Petitioner's farm losses
compared to her other income5 are as follows:
Year Schedule F Losses Nonfarm Income
1985 $18,412 $26,813
1986 30,321 34,404
1987 33,431 28,578
1988 27,404 43,652
1989 36,740 28,917
1990 33,260 24,368
1991 11,093 17,034
1992 30,054 39,791
1993 23,463 14,795
244,178 258,352
5 This includes gross income from Foxcroft, Oregon State
Board of Higher Education, interest and dividend income, and
income from pensions from the State of Oregon Public Employees
Retirement System and Portland Community College.
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