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in economics. For the taxable years at issue, petitioner worked
as one of several farm managers.
In his capacity as manager, petitioner is required to live
on or in close proximity to the farm. He has personnel to manage
on a daily basis. Each morning, petitioner awakens to laborers
waiting outside his house in hopes of getting work for the day.
Petitioner is responsible for hiring and firing these laborers,
as needed, on the land he oversees.
Petitioner also must be available at various times of the
day and night as part of his management of the land. The hops
season runs for 11 months out of the year, with a 6-month cycle
of around the clock irrigation. The laborers work 24 hours a day
in August to harvest the 1,300-acre crop. The apple orchard
requires 24-hour attention from April through October, and the
cattle require 24-hour attention during calving season. During
irrigation season, the managers must watch for broken pipes, and
during frost season, managers are on call for frost alarms which
require immediate response. Farming equipment must be closely
monitored to avoid vandalism and to ensure the security of the
machinery. For this reason, petitioner sometimes stores farming
vehicles and other equipment on his property.
In addition to tractors and trucks, petitioner also provides
storage space for ladders and packing boxes that are used
throughout the season. On the 5-acre parcel of land surrounding
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Last modified: May 25, 2011