- 21 - the farming activity and the holding of the land cannot be construed to be a single activity. Petitioners may not utilize the appreciation of the land to support their argument that it should offset the farming losses. See also Hoyle v. Commissioner, T.C. Memo. 1994-592. In that regard, we find that petitioners’ expenditures and primary intent were, as evidenced by the nature of their activity and claimed losses, attributable to farming rather than improvement of the realty. The Success of the Taxpayers in Carrying On Other Activities. Petitioners did not present any evidence that they had been previously engaged in farming activities, or similar activities. Petitioner husband was successful in his professional activities, but there is no showing that he employed his fiscal and financial experience from his professional activity in his farming activity. Amount of Occasional Profit. Petitioners have not earned any profit from the farming activity during any of the years about which there is evidence in the record. The Financial Status of the Taxpayers. Substantial income from sources other than the activity in question, especially if the losses generate significant tax benefits, may indicate that the activity is not engaged in for profit. Sec. 1.183-2(b)(8),Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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