-13- Before, during, and after the years in issue, the limited time petitioner spent working in the cattle ranch activity is inconsistent with a legitimate for-profit objective. The lack of formal books and records, of a ledger, of a budget, and of a meaningful business plan for the ranch indicates that petitioners’ ranch activity was not carried on in a businesslike manner. Petitioners used the ranch for a personal residence and apparently intended to retire there. Petitioners’ ranch activity realized losses every year, and from 1983 through 1997 it accumulated, before depreciation, approximately $700,000 in total losses. Petitioner acknowledges that he had no expectation of realizing income from the ranch in any of the early years. Petitioner states that his intention for the ranch was, over the course of 15 years, to retain female calves born each year and, by breeding the cows, to build up the cattle herd to 500 mature cows and to build up the total ranch acreage to 2,000 acres. At that point, by the sale of female calves that would be born each year, petitioner claims that he expected the cattle ranch to provide comfortable retirement income for him and his wife. Petitioner’s assertions as to his long-term strategy with regard to the ranch are undermined by the lack of breeding and calving records and by petitioners’ sale each year (at leastPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011