-12- Losses Gross (including Year receipts Interest depreciation) Depreciation 1983 $10,593 $9,535 ($37,950) $8,372 1984 3,875 12,574 (32,786) 4,090 1985 6,212 5,270 (35,469) 15,330 1986 16,791 -0- (189,357) 27,986 1987 152,256 92,488 (441,830) 62,513 1988 124,778 165,686 (597,344) 112,479 1989 112,918 242,162 (665,058) 153,479 1990 156,342 278,819 (618,068) 163,002 1991 229,360 207,716 (436,238) 128,721 1992 163,245 167,674 (394,552) 126,696 1993 166,079 143,677 (431,075) 61,849 1994 114,463 153,340 (418,001) 41,582 1995 117,872 197,563 (474,332) 56,055 1996 107,276 224,345 (595,778) 79,213 Respondent mailed a notice of deficiency to petitioner on March 25, 1996. Respondent determined that Broadmoor Gardens and petitioner's farm were separate activities and disallowed petitioner's deductions for depreciation and other business expenses related to Broadmoor Gardens. Petitioner timely filed her petition on June 17, 1996. II. OPINION A. Whether Petitioner's Farm and Broadmoor Gardens Undertakings Were Separate Activities We must decide whether petitioner's farm and Broadmoor Gardens were one or two activities in 1990 and 1991. The applicable regulations state that, generally, the most important factors in deciding whether two or more undertakings are operated as one activity or separate activities are the degree of organizational and economic interrelationship of thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011