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Single Activity
In order to apply section 183 and the regulations
promulgated thereunder, the activity or activities of the
taxpayer must be ascertained. Sec. 1.183-1(d)(1), Income
Tax Regs. According to the regulations under section 183,
in ascertaining the activity or activities of the taxpayer,
the general rule is that all the facts and circumstances
of the case must be taken into account. Id. The regula-
tions provide as follows:
Generally, the most significant facts and
circumstances in making this determination
are the degree of organizational and economic
interrelationship of various undertakings, the
business purpose which is (or might be) served by
carrying on the various undertakings separately
or together in a trade or business or in an
investment setting, and the similarity of various
undertakings. Generally, the Commissioner will
accept the characterization by the taxpayer of
several undertakings either as a single activity
or as separate activities. The taxpayer's
characterization will not be accepted, however,
when it appears that his characterization is
artificial and cannot be reasonably supported
under the facts and circumstances of the case.
* * * [Id.]
Petitioners treat their fish, Christmas tree, timber,
and row crop undertakings as a single activity for section
183 purposes. Respondent does not suggest otherwise.
Given the economic and organizational interrelationship of
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