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),
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