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none of decedent's individual income tax returns for 1989-93 (the
only income tax returns of decedent in the record) reports any
income or loss from a partnership.
Finally, we note that for the fiscal years ending in
February 1985 and February 1986, almost all family farm income
reported by Garry’s estate was rental income. For the fiscal
years ending in 1987 through 1993, the estate reported its farm
income simply as “other income”, but it also reported that the
principal activity of the family farm was “land rental”. For the
fiscal year ending in February 1994, the estate reported its farm
income on Form 4835, Farm Rental Income and Expenses. At trial,
Donald Hendrickson testified that in 1984 or 1985 he began
farming various portions of the family farm land formerly rented
to tenant farmers, and that by 1992 he was farming almost all of
the family farm land. He also testified that the other children
and he were conducting this farming as “tenants”.
All these facts strongly suggest that there was no family
farm partnership of any kind among decedent and the children,
much less a partnership that conducted the farming operations on
the family farm land. However, even if we assume that a farm
partnership existed in the form claimed by petitioner--and also
assume that decedent transferred her net investment income to
that partnership--decedent’s transfers would not meet the "bona
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