9 Mendoza are very similar to those before us today. The taxpayer in that case was an attorney who claimed that his polo activity was conducted to obtain clients. We found that any benefit to the legal practice from the polo activity was at best incidental. We make a similar holding today. Petitioner has failed to establish any correlation between the ranching activity and the medical corporation. We think it is significant that the three parcels of land making up petitioners' farm or ranch were purchased separately by them, were apparently never conveyed to the Institute to augment its assets, nor merged into the Institute's accounts, and the losses therefrom were claimed in petitioners' tax returns as a deduction, without reference to the Institute. The only connection between petitioner's ranch activity and the medical practice of the Institute was the rather vague assertion by petitioner that the publicity he derived from playing polo helped him get patients for his cosmetic surgery. Such argument was not supported by any patient of petitioner or by any other witness or evidence herein. To us, it is at least as far fetched and unconvincing as was the alleged connection between a legal practice and polo in De Mendoza v. Commissioner, supra. B. The Conduct of the Ranch for Profit We must decide whether petitioners conducted their ranching and ranching-related activities with a profit objective for the 1989 and 1990 tax years. To meet his burden, Rule 142(a),Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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