Mary Ann Tobin - Page 15




                                        -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 that               






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