- 39 -
especially if there are personal or recreational
elements involved.
Petitioner realized substantial income from sources
other than the farming activity during the years in issue.
Petitioner worked as a district sales manager for State
Farm during the years in issue, earning an average of
approximately $193,000 per year in wages. Petitioners also
received income from their investment in the Holt Shopping
Center of approximately $20,000 per year. This, combined
with the fact that their farming activity generated
aggregate losses of $206,000 over the years in issue,
strongly indicates that petitioners did not engage in their
farming activity with an actual and honest objective of
earning a profit. See Sutton v. Commissioner, 84 T.C. 210,
222-226 (1985), affd. 788 F.2d 695 (11th Cir. 1986), affd.
sub nom. Knowlton v. Commissioner, 791 F.2d 1506 (11th Cir.
1986); Golanty v. Commissioner, 72 T.C. 411, 426-429
(1979), affd. without published opinion 647 F.2d 170 (9th
Cir. 1981); Jasionowski v. Commissioner, 66 T.C. 312, 322
(1976); Vallette v. Commissioner, T.C. Memo. 1996-285;
Hoyle v. Commissioner, T.C. Memo. 1994-592.
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