Mary Ann Tobin - Page 14




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          activities.  Respondent contends:  (1) Broadmoor Gardens and the            
          farm did not have a close organizational and economic                       
          interrelationship, (2) petitioner had no business purpose for               
          operating Broadmoor Gardens and the farm as one activity, and (3)           
          Broadmoor Gardens and the farm were not similar activities.                 
               We have applied various factors in deciding whether a                  
          taxpayer's characterization of two or more undertakings as one              
          activity is unreasonable for purposes of section 183, such as:              
          (a) Whether the undertakings share a close organizational and               
          economic relationship, (b) whether the undertakings are conducted           
          at the same place, (c) whether the undertakings were part of a              
          taxpayer's efforts to find sources of revenue from his or her               
          land, (d) whether the undertakings were formed as separate                  
          businesses, (e) whether one undertaking benefited from the other,           
          (f) whether the taxpayer used one undertaking to advertise the              
          other, (g) the degree to which the undertakings shared                      
          management, (h) the degree to which one caretaker oversaw the               
          assets of both undertakings, (i) whether the taxpayers used the             
          same accountant for the undertakings, and (j) the degree to which           
          the undertakings shared books and records.  See Keanini v.                  
          Commissioner, 94 T.C. 41, 46 (1990); Estate of Brockenbrough v.             
          Commissioner, T.C. Memo. 1998-454; Hoyle v. Commissioner, T.C.              
          Memo. 1994-592; De Mendoza v. Commissioner, T.C. Memo. 1994-314;            
          Scheidt v. Commissioner, T.C. Memo. 1992-9.                                 






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