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close organizational and economic relationship. Rodeo and horse
undertakings are complementary. The undertakings were both
conducted at petitioners' farm and were both attempts to make the
farm profitable. Mr. Brockenbrough and Bumgarner managed the
rodeo and horse undertakings and their assets. Petitioners held
rodeos in part to boost their horse business. Petitioners used
some of their horses and cattle, the barn, and arena for both the
farm and rodeos. Petitioners used the rodeos to advertise and
sell their quarter horses. Petitioners used the same accountant
for the horse and rodeo undertakings. Petitioners used the same
checking account for their rodeo and horse undertakings and
reported both undertakings on one schedule for each year in
issue.
In Hoyle v. Commissioner, supra, the taxpayer bought a farm
and then grew raspberries, soybeans, corn, and grain; guided
hunting; boarded horses; raised horses and cattle; bred game
birds; crabbed; raced thoroughbred horses; and participated in
agricultural set-asides. According to Hoyle, those undertakings
were one activity for purposes of section 183. This case is like
Hoyle v. Commissioner, supra, in that petitioners were trying to
find sources of revenue from their farm. See also Sparre v.
Commissioner, T.C. Memo. 1980-45 (grain farm and gun club were
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