- 3 - 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 surroundingPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011