James M. Goforth and Brenda Goforth - Page 9




                                        - 9 -                                          

          the ranch indicate that the ranch activity was not carried on                
          in a businesslike manner.  Petitioner derived personal                       
          satisfaction from raising what he believed were superior cattle              
          and from awards the cattle won.  Petitioners used the ranch for              
          a weekend retreat, and petitioners intended to retire on the                 
          ranch.  In order to be profitable, petitioners needed to                     
          maintain at least 140 head of cattle on the ranch.  The ranch                
          however, supported only a maximum of 100 head of cattle,                     
          precluding any profit from the ranch (except for 1995 when                   
          petitioner liquidated his herd of cattle for a small profit).                
          From 1983 to 1996, petitioners’ ranch activity accumulated                   
          losses of more than $1.7 million.                                            
               Based on the evidence, we conclude that petitioners have                
          failed to establish that an actual and honest profit objective               
          was associated with petitioners’ ranch activity.                             
               To reflect the foregoing,                                               
                                                   Decision will be entered            
                                              for respondent.                          
















Page:  Previous  1  2  3  4  5  6  7  8  9  

Last modified: May 25, 2011