-16- 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 isPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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