-17-
operated as a joint venture, or that two undertakings may not be
one activity just because each does not depend on the success of
the other.
Respondent contends that petitioner's farm and gardens are
too dissimilar to be one activity, and that petitioner had no
business purpose for operating the two undertakings together.
Respondent characterizes Broadmoor Gardens as a tourist
attraction and contends that a tourist attraction is clearly
separate from a farm. We disagree. The taxpayers in Hoyle v.
Commissioner, supra, and Sparre v. Commissioner, T.C. Memo. 1980-
45, attempted to attract the public to their farms to participate
in undertakings they devised in an attempt to supplement their
income from traditional farming activities, including guided
hunting, a gun club, and crabbing. In Hoyle v. Commissioner,
supra, the taxpayer grew raspberries, soybeans, corn, and grain;
guided hunting; boarded horses; raised horses and cattle; bred
game birds; had a crabbing venture; raced thoroughbred horses;
and participated in agricultural set-asides. According to Hoyle,
those undertakings were one activity for purposes of section 183.
This case is like Hoyle v. Commissioner, supra, and Estate
of Brockenbrough v. Commissioner, supra, in that petitioner was
trying to find sources of revenue from her farm. It is also
similar to cases where we held that horse breeding and other
undertakings involving horses were one activity. See, e.g.,
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