S.K. Johnston, III and Julie N. Boyle f.k.a. Julie N. Johnston, et al. - Page 19

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            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 agribusiness                             






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