- 5 - apples, petitioner grows the apples, picks and bags them, and then takes the bags to his offices for sale to his patients. Thus, petitioner considers his apple orchard an integral part of his dental practice. Petitioner testified that he has tried, but prefers not, to sell the apples commercially. Some of the apples have suffered injury from insects and are otherwise marked which makes much of his fruit less valuable on the commercial market; thus, in petitioner's opinion the profit margin from commercial sales is not good. Instead, he prefers to grow the best, most nutritious apples that he can and provide them to his patients. If a patient cannot afford to purchase the apples, petitioner gives them to the patient without charge. Petitioner estimates that of all his patients, only 10 or 15 percent avail themselves of the apples. There is no question that petitioners have never made a profit with respect to the apple orchard activity during their 14-year involvement with the fruit. Petitioners' Tax Returns Petitioners formed a partnership, Twin Creeks Organic Farm, in 1992. Petitioners are the only partners in the partnership. For reporting purposes, petitioners combined their dentistry activity gross receipts with their apple orchard activity income and expenses on one Form 1065 (U.S. Partnership Return of Income). In each of the years at issue, petitioners reported thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011