Anthony W. Jorgenson and Florence A. Jorgenson - Page 14




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               A.  Manner in Which the Activity Is Conducted                          
               The fact that a taxpayer carries on the activity in a                  
          businesslike manner and maintains complete and accurate books and           
          records may indicate a profit objective.  See sec. 1.183-2(b)(1),           
          Income Tax Regs.  Petitioners presented the Court with voluminous           
          receipts, invoices, and canceled checks allegedly evidencing                
          expenditures for the four properties.  After reviewing the                  
          evidence, we cannot determine whether the expenditures were                 
          exclusively for the benefit of the four properties (instead of              
          the rental properties) and which expenditures, if any, related to           
          which specific ranch or farm.                                               
               The parties also stipulate that petitioners did not prepare            
          any budget or operating statements.  Further, the parties                   
          stipulate that petitioners did not create a written business plan           
          or any financial projections.  Petitioners conducted their                  
          activities unaware of the amount of revenue they could reasonably           
          generate and had no credible estimate of the costs associated               
          with the four properties.                                                   
               We conclude that petitioners did not conduct the ranching              



          as a separate activity.  In order to ascertain whether                      
          petitioners have conducted separate activities, we must evaluate            
          all the facts and circumstances of the case.  See sec. 1.183-               
          1(d)(1), Income Tax Regs.  Although we find that the ranching and           
          farming activities on the four properties are one activity, we              
          note that the outcome of this case would have been the same had             
          we concluded that petitioners maintained separate activities on             
          each of the four properties or two activities (one for ranching             
          and one for farming).                                                       



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