- 35 -
connection with his business. The cellular phone,11 which is
installed in petitioner's van, is not listed under TSI.
Petitioner did not provide any telephone bills for the amounts in
issue to establish what portion, if any, is business related. We
also note that the telephone bills submitted in connection with
deductions claimed for petitioner's farm activity, TSR, are
surprisingly low, less than $20 per month. This leads to the
conclusion that petitioners were making personal calls from the
so-called business phone. Accordingly, we find for respondent
since petitioner failed to meet his burden of proof. Sec. 162.
Issue 4. Schedule F Farm Activity
Respondent determined that petitioners did not engage in
their farm activity with the intent to earn a profit. In accord
with section 183, respondent disallowed the losses claimed on
petitioners' Schedule F, resulting from farm expenses of $28,327
and $37,747 for 1991 and 1992, respectively. Petitioners assert
that they entered into and carried on their farm activity in good
faith and with the intent to earn a profit, and therefore the
losses arising from the farm activity are allowable.
Section 183(a) provides that if an activity is not engaged
in for profit, "no deduction attributable to such activity shall
11 A cellular phone is listed property under sec.
280F(d)(4)(A)(v).
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