-14-
through 1992 and possibly through 1993) of all their female
calves.1 These circumstances speak loudly to the nonprofit
nature of petitioners’ cattle ranch activity, particularly where
the buildup of the cattle herd and the profit were to be based on
the successful breeding of the cows.
Petitioners claim that the for-profit nature of the cattle
ranch is indicated by, among other things, the no-frills nature
of the property, the lack of recreational use of the property,
and the alleged long-range plan or purpose to use income from the
ranch to support petitioners in their retirement. With regard
specifically to the alleged long-range plan, petitioners offered
into evidence a calendar for 1983 on which were entered a few
brief words as follows:
Retire age 60 — 1998
2500 acres paid
500 mama cows paid
We do not believe that this brief calendar entry adequately
corroborates the existence of a long-range business or profit
plan for the ranch. Rather, we regard the calendar entry as
reflecting, at most, a general goal or desire. The credible
1 The parties have stipulated that “During the years 1982
through 1993, petitioners sold the cattle raised each year.”
Petitioner testified, on the other hand, that he temporarily
stopped selling heifers after a 1992 price drop. To the extent
there is a discrepancy, we do not view it as material to our
analysis or to the result reached herein.
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