-15- Applying these factors, we conclude that the farm and Broadmoor Gardens undertakings were one activity. Petitioner's farm and Broadmoor Gardens had a close organizational and economic relationship. Both undertakings were conducted at petitioner's farm, and both were attempts to make the farm profitable. Petitioner used her farmland for both undertakings. Petitioner created and developed Broadmoor Gardens in an attempt to replace tobacco as the farm's main cash crop. Both the gardens and the farm required the planting, tending, and harvesting of plants or crops. Petitioner managed both undertakings as one activity. The farm and Broadmoor Gardens shared the same employees and equipment. Richardson was the accountant for both undertakings. Petitioner used the same checking account and books for her farm and Broadmoor Gardens and reported both undertakings on one Schedule F in each of the years in issue. Respondent points out that petitioner reported income from different undertakings, such as tobacco leases, corn subsidies, and horse and cattle sales, on her Schedules F, and that the common ownership of several undertakings does not mean they are a single activity. Respondent maintains that the only farming activity conducted on petitioner's farm was the raising and selling of cattle and horses, and that this activity was conducted away from petitioner's residence. We disagree thatPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011