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contended that he was unable to implement that project because of
disputes concerning the water usage. Other than a drought in
1987, the litigation concerning the reservoir apparently was not
an impediment to petitioners' use of the reservoir for raising
fish.
Petitioners testified that significantly increasing the size
of their livestock herd would result in profitability for their
farming venture; however, their herd remained approximately the
same during the years at issue (25 cattle and 60 sheep) and at
the time of trial (22 cattle and 65 sheep).
The Expertise of the Taxpayers or Their Advisers.
Petitioners were not experienced farmers, and although petitioner
wife had some experience in raising game birds, she did not
demonstrate that she took steps to successfully operate a farm.
Petitioners attempted to become knowledgeable about the market
for cattle and sheep; they sought advice from local farmers, read
farming materials from the San Mateo Farm Bureau, and consulted
with various institutions such as the University of California at
Davis, as well as the U.S. Department of Soil Conservation.
Time and Effort Expended by the Taxpayers in Carrying On the
Activity. Petitioners expended significant time in the farming
activity. Petitioner husband worked full time as an engineer,
and he also worked approximately 30 hours a week (10-12 hours per
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