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though he did say that he was too busy with other activities to
take care of the farm.
Each Schedule F from 1981 to 1990 reflected a net loss,
totaling $984,221. While petitioner stated that he has always
farmed and that “this wasn’t a hobby farm like a lot of people”,
we have been unable to find any evidence establishing that
petitioner engaged in the farming activities with the intention
of making a profit.
During trial, petitioner alluded to the fact that the IRS
wrote to him or Mr. Grierson, his return preparer, stating that
$455,000 worth of Schedule F losses could be used for the first
year that there was taxable income. Neither petitioner nor Mr.
Grierson, however, was able to produce any document from the IRS
regarding the availability of any Schedule F losses. Indeed, Mr.
Grierson admitted that the conversation regarding the Schedule F
losses may have been between himself and petitioner rather than
between himself and the IRS.
Based on petitioner’s testimony and the lack of any evidence
regarding the manner in which he conducted his activity, we find
that petitioner has not established that making a profit was his
primary objective. Furthermore, petitioner has also failed to
substantiate the claimed losses. Accordingly, we sustain
respondent’s determinations regarding petitioner’s Schedule F net
loss deductions for the 1987, 1988, 1989, and 1990 tax years.
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