- 16 - 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 perPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011