- 24 -
sort of feed, and several salt licks in or around the
wooded areas. After he toured the property, Mr. Przytulski
asked Mr. Jackson, petitioners' accountant, for invoices
and receipts to support petitioners' canceled checks. In
response, Mr. Jackson offered Mr. Przytulski a disorganized
assortment of documents. Although Mr. Przytulski asked
Mr. Jackson to organize the documents, he never received
the documentation he requested in an organized format.
In April 1992, Revenue Agent Robert Cole visited
petitioners' property in conjunction with his audit of
their 1989 through 1991 returns. After touring the
property, Mr. Cole asked Mr. Jackson to produce documents
to support petitioners' deductions during those years.
Once again, Mr. Jackson offered Mr. Cole a box of
disorganized records which included documents relating to
all of petitioners' checking accounts, including their
personal accounts. Petitioners never provided Mr. Cole
with a summary reconciling their tax return entries with
the documents they produced.
OPINION
Section 183
The primary factual issue in this case is whether
petitioners' farming activity was an "activity not engaged
Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: May 25, 2011