- 13 - ledgers, invoices, or canceled checks. Petitioners did not prove that the Double D Ranch, Inc., incurred any expenses which could be classified as ordinary and necessary. A taxpayer claiming a deduction under section 162 or 212 for an expense, or under section 165 for a loss, must have an "actual and honest profit objective" in order to avoid the disallowance of such deductions. See sec. 183; Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983). Mr. Streck testified that petitioners initially purchased a ranch located in Kentucky as "a getaway because I was working in New York and traveling all the time and we wanted to get out in the country." The ranch was later incorporated under the name Double D Ranch, Inc. Although petitioners apparently engaged in some farming, Mr. Streck testified that the farming activity was a "total disaster". Throughout the time petitioners owned Double D Ranch, Inc., they continued to use the log cabin constructed on corporate property as a personal residence and use the boat dock located on corporate property for pleasure. Petitioners failed to provide evidence of an actual and honest objective to make a profit. We sustain respondent's disallowance of deductions that petitioners claimed with respect to Double D Ranch, Inc. The next issue is whether Mrs. Streck qualifies as an innocent spouse pursuant to section 6013(e). Generally, a husband and wife are jointly and severally liable for the totalPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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