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petitioner's various undertakings are not part of a single
farming activity. Raising crops and animals, leasing cropland,
and participating in a Government agricultural subsidy program
may be one activity if they are attempts by the farmer to
generate income from the farm. See, e.g., Hoyle v. Commissioner,
supra.
Respondent relies on Drummond v. Commissioner, T.C. Memo.
1997-71, affd. in part and revd. in part without published
opinion 155 F.3d 558 (4th Cir. 1998), for the proposition that
two farm undertakings that are not conducted on the same land are
separate activities. Respondent's reliance on Drummond v.
Commissioner, supra, is misplaced. In Drummond, we held that the
taxpayer's horse and cattle undertakings were separate activities
because we were not convinced that the taxpayer intended to use
his herd of cattle to manage the pasture for his horses. In
contrast, petitioner operated the gardens and farm as one
activity.
Respondent contends that Broadmoor Gardens and petitioner's
farm were separate activities because petitioner and Ms. Beard
operated the gardens as a joint venture. Respondent also
contends that the farm and Broadmoor Gardens did not depend on
the success of the other. We disagree. Respondent cites no
reason or authority to support the contentions that an
undertaking may not be part of an activity just because it is
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