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$500 per tree. Petitioners therefore assert that the appreciated
value of the land plus the trees will more than offset any losses
they take on current tax returns.
Other than petitioner's self-serving testimony, there is no
evidence on record to support his assertion of the value of the
trees. Although as coowner of the apple trees, petitioner is
qualified to testify as to their value, we are not required to,
and we do not, accept his self-serving testimony on this point.
Harmon v. Commissioner, 13 T.C. 373, 383 (1949).
Even if we accepted, arguendo, petitioner's valuation of the
apple trees, and that petitioners have held the Tiller property
with the expectation of making an overall profit from the
operation due to the appreciation of the value of the land, this
factor would still not favor petitioners. The last sentence of
section 1.183-2(b)(4), Income Tax Regs., cross-refers to
paragraph (d) of section 1.183-1 for a definition of an activity
in this connection. Section 1.183-1(d)(1), Income Tax Regs.,
provides:
Where land is purchased or held or held primarily with
the intent to profit from increase in its value, and
the taxpayer also engages in farming on such land, the
farming and the holding of the land will ordinarily be
considered a single activity only if the farming
activity reduces the net cost of carrying the land for
its appreciation in value. Thus, the farming and
holding of the land will be considered a single
activity only if the income derived from farming
exceeds the deductions attributable to the farming
activity which are not directly attributable to the
holding of the land (that is, deductions other than
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