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1.183-1(d), Income Tax Regs., provides that, in determining
whether several undertakings of a taxpayer constitute one activ-
ity or two or more separate activities for purposes of section
183, we must consider all of the facts and circumstances, includ-
ing: (1) The degree of organizational and economic interrela-
tionship of the undertakings, (2) the business purpose, if any,
that is served by carrying on the undertakings separately or
together, and (3) the similarity of the two undertakings.
Petitioner argues that, during 1990 and 1991, his horse
activity and his cattle activity constituted a single activity
for purposes of section 183 because he planned to expand his herd
of cattle and to use that cattle to help manage the pasture for
his horses. On the record before us, we reject petitioner's
argument. Except for petitioner's self-serving testimony on
which we are unwilling to rely, there is no evidence in the
record to support petitioner's assertion that, during 1990 or
1991, he planned to expand his herd of cattle and use them for
pasture management or that he thereafter took any measures to
implement that alleged plan. In fact, petitioner did not even
keep the cattle and the horses on the same land during 1990 and
1991; they were not kept on the same land until sometime around
1993 or 1994.
On the record before us, we find that petitioner has failed
to establish that, during 1990 and 1991, his horse activity and
his cattle activity constituted one activity for purposes of
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