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expenditures that form the basis of the subject losses.
For example, respondent's agent testified that he saw salt
licks and deer tracks near wooded areas on the property and
wooden boxes containing some sort of feed near the ponds.
Although petitioner testified that he did not hunt on his
land, it is evident that he made some effort to attract
wildlife to the property.
We also note that the building petitioners claim to
have constructed for State Farm meetings resembles a
hunting lodge more than a business office. Further,
petitioner testified that only one State Farm meeting was
held in the building. Moreover, although petitioner
testified that he did not eat fish, he admitted that his
family had eaten fish taken from the ponds. In light of
all these circumstances, we find that petitioners derived
an element of recreational and personal benefit from their
farming activity.
In light of all of the facts and circumstances of
this case, we sustain respondent's determination that
petitioners' farming activity was an "activity not engaged
in for profit" within the meaning of section 183. We
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