-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
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011