- 19 - including boarding polo ponies, which brought in substantial revenues, and developing the wildlife habitat in an effort to generate revenue from hunting, fishing, and recreational use. Thus, viewing the record as a whole, we hold that the Johnstons engaged in their farm activity with a bona fide intent to make a profit. Accordingly, the losses incurred in such activity during the years in issue are fully deductible. Issue 2. Whether Petitioners' Ranching Activity Known as Flying H Ranch Was an Activity Engaged in For Profit Flying H Ranch In December 1985 petitioner acquired a 1,381-acre tract of rangeland, known as the Flying H Ranch, located on the eastern slope of the Bighorn Mountains near Sheridan, Wyoming, in north- central Wyoming, close to the Montana border. Subsequent purchases of 2,367 acres in December 1986, 925 acres in April 1989, and 3,902 acres in October 1989 increased Flying H to 8,575 acres, its size during the years in issue. The ranch property is rural rangeland, which is located approximately 5 miles from the Bighorn Equestrian Center, and approximately 250 miles from the Flying D Ranch, owned by Ted Turner, which is considered to be in the same general area by those traveling out west to hunt. Flying H is a multi-use activity. Petitioner hired MacCarty, a well-respected and qualified rancher, to manage Flying H, and Dr. Haaland, an agribusinessPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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