Ralph E. Wesinger, Jr. and Catherine R. Wesinger - Page 27




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          respect to the SRMC business, and drought conditions in the area            
          of the ranch as responsible for his continued losses.  We                   
          disagree that these circumstances are sufficient to justify the             
          lengthy period of losses at issue.                                          
               The hurricane and the SRMC misfortunes are only tangentially           
          related to the ranching enterprise.  In addition, the hurricane             
          damage was resolved within a relatively short period, impacting             
          only the winter of 1992-93, so cannot explain the many years of             
          losses.  As to SRMC’s reverses, since petitioner’s level of                 
          involvement in ranch affairs prior to the 1993 corporate problems           
          does not appear to differ significantly from his subsequent                 
          activities, the SRMC hardships are a less than convincing reason            
          for losses at the ranch.                                                    
               The alleged drought, too, falls short of offering a                    
          legitimate excuse.  Petitioner testified that he learned of the             
          dry conditions after he bought parcel 1 in 1990, so the lack of             
          rainfall was hardly unforeseen when parcel 2 was purchased in               
          1992.  Prior to the years at issue, petitioner should have been             
          aware of the need to plan for such conditions if he truly                   
          intended to make a profit from his property.  As of early 1999,             
          an irrigation system was still not in place on the property.                











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