Terry F. and Carol J. Zdun - Page 13

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          accurate books and records, whether the activity was conducted in           
          a manner substantially similar to comparable businesses that are            
          profitable, and whether changes were attempted in order to                  
          improve profitability.  Engdahl v. Commissioner, 72 T.C. 659,               
          666-667 (1979).                                                             
               Petitioners assert that they have maintained records for               
          their activities.  However, their books of account for the apple            
          orchard consist of their bank deposit slips, check stubs, and tax           
          forms.  Petitioners have two bank accounts, one in the name of              
          petitioner and the other in the name of Twin Creeks Farm.                   
          Petitioner testified that when he received money, from whatever             
          source, he deposited it in whichever account needed the money.              
          He further testified that he used both accounts as family                   
          accounts.                                                                   
               Petitioners did not present any production records for the             
          apple orchard.  In fact, at trial petitioner was not even certain           
          of the exact number of trees in the orchard.  Thus, we find that            
          petitioners kept no separate complete and accurate books or                 
          production records for the orchard activity.                                
               Although petitioners' tax preparer, Susan Bladorn-Dukes,               
          testified that petitioners' canceled-checks method of recording             
          income and expenses was much like that of other farmers for whom            
          she prepares tax returns, she also testified that most of those             
          farms were "absolutely not" self-supporting.  Thus, we do not               





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