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We have applied various factors in deciding whether a
taxpayer's characterization of several undertakings as one
activity is unreasonable for purposes of section 183, such as:
(a) Whether the undertakings share a close organizational and
economic relationship, (b) whether the undertakings are conducted
at the same place, (c) whether the undertakings were part of a
taxpayer's efforts to find sources of revenue from his or her
land, (d) whether the undertakings were formed as separate
businesses, (e) whether one undertaking benefited from the other,
(f) whether the taxpayer used one undertaking to advertise the
other, (g) the degree to which the undertakings shared
management, (h) the degree to which one caretaker oversaw the
assets of both undertakings, (i) whether the taxpayers used the
same accountant for the undertakings, and (j) the degree to which
the undertakings shared books and records. Keanini v.
Commissioner, 94 T.C. 41, 46 (1990); Hoyle v. Commissioner, T.C.
Memo. 1994-592; De Mendoza v. Commissioner, T.C. Memo. 1994-314;
Scheidt v. Commissioner, T.C. Memo. 1992-9; Trafficante v.
Commissioner, T.C. Memo. 1990-353; Schlafer v. Commissioner, T.C.
Memo. 1990-66.
Applying these factors, we conclude that the undertakings at
issue were one activity. The rodeo and horse undertakings had a
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