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Petitioners have never engaged in any undertakings
similar to their "farming" activity. However, petitioners
have been successful in several dissimilar business
activities. Sometime prior to the years in issue,
petitioners purchased an interest in a shopping center
which consistently generates a profit. Petitioners also
invested in a tennis villa, a resort villa, and other
residential property in Florida, but there is no
documentary evidence in the record to substantiate
petitioners' vague testimony that they realized profits
from these activities. Additionally, Mrs. Holmes owns a
retail clothing business which incurred a loss of $584 in
1990 and realized a profit of $179 in 1991.
Although we recognize that petitioners may have been
successful with respect to dissimilar activities in the
past, this does not indicate that they are engaged in their
farming activity for profit. Petitioners have realized
significant losses from that activity during the years in
issue and thereafter. Moreover, petitioners' residence is
located on a portion of their property and it is reasonable
to conclude that some part of the expenditures at issue
benefited petitioners' residence or petitioners' enjoyment
of their residence.
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