Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 24

                                       - 24 -                                         
          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              









Page:  Previous  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  Next

Last modified: May 25, 2011