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