- 24 - 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.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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