- 13 - 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 notPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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