Debra L. Streck and Donald W. Streck - Page 13

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          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 total             




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