- 12 - boarded at any given time. Bendabout also lost one of its best clients, whose polo career ended when he was shot. Another part of petitioner's business plan for Bendabout was to develop the wooded areas of the farm for a wildlife habitat in order to generate revenue from hunting, fishing, and recreational use. Dove hunting, deer hunting, and quail hunting were all available at Bendabout during the years in issue. Food patches for quail were planted throughout the woods. Several open fields were planted with species that benefit both dove and quail. Bendabout had approximately 4 acres of water, including Woods Lake, Boone Lake, Barn Lake, and Silo Pond which were available for fishing during the years in issue. Discussion Respondent determined that the Johnstons did not engage in their farm activity with the intent to earn a profit, and therefore pursuant to section 183 disallowed the related Schedule F losses for the years in issue. Petitioners assert that they entered into and carried on Bendabout with the intent to earn a profit, and therefore their losses are allowable. Section 183(a) provides that if an activity is not engaged in for profit, "no deduction attributable to such activity shall be allowed", except as otherwise provided in section 183(b).7 7 Sec. 183(b)(1) provides that deductions which would be allowable without regard to whether such activity is engaged in for profit shall be allowed, such as interest and State and local taxes. Sec. 183(b)(2) provides that deductions which would be (continued...)Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011