Robert E. and Carloyn S. Holmes - Page 28

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             these activities, we accept petitioners' characterization.               
                  Neither party addressed, either at trial or on brief,               
             whether the holding of the land for its appreciation in                  
             value should be treated as a separate activity for section               
             183 purposes.  On this point, the regulations provide in                 
             pertinent part as follows:                                               

                  Where land is purchased or held primarily with                      
                  the intent to profit from increase in its value,                    
                  and the taxpayer also engages in farming on such                    
                  land, the farming and the holding of the land                       
                  will ordinarily be considered a single activity                     
                  only if the farming activity reduces the net                        
                  cost of carrying the land for its appreciation                      
                  in value.  Thus, the farming and holding of the                     
                  land will be considered a single activity only                      
                  if the income derived from farming exceeds the                      
                  deductions attributable to the farming activity                     
                  which are not directly attributable to the                          
                  holding of the land (that is, deductions other                      
                  than those directly attributable to the holding                     
                  of the land such as interest on a mortgage                          
                  secured by the land, annual property taxes                          
                  attributable to the land and improvements,                          
                  and depreciation of improvements to the land).                      
                  [Sec. 1.183-1(d)(1), Income Tax Regs.]                              

             The above-quoted provision of section 1.183-1(d)(1), Income              
             Tax Regs., applies only where "land is purchased or held                 
             primarily with the intent to profit from increase in its                 
             value".  See Engdahl v. Commissioner, 72 T.C. 659, 668 n.4               
             (1979); Hoyle v. Commissioner, T.C. Memo. 1994-592; sec.                 
             1.183-1(d)(1), Income Tax Regs.  Because it does not appear              
             that petitioners' primary intent was to profit from                      





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