Robert and Karen O'Connor - Page 16




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               Petitioners argue that Omega was financially unable to make            
          changes to its farming methods and that property liens kept them            
          from obtaining loans to improve the farm and its profitability.             
          Petitioners’ argument does not ring true.  Omega’s net income,              
          after accounting for farming losses was $217,787, $483,949, and             
          $660,375 for 1993, 1994, and 1995, respectively.  Therefore,                
          Omega was capable of acquiring livestock, providing irrigation              
          for the almond orchard, and/or purchasing new trees to replace              
          unproductive ones.                                                          
               Omega’s profitable business activity was hauling and                   
          recycling rubbish, and petitioner admits that he had little                 
          experience with farming.  He argues, however, that his                      
          consultations with experts demonstrate petitioners’ ongoing                 
          effort to bring Omega’s farming activity into profitability.                
               Petitioners did present evidence that advice was sought and            
          received concerning increasing herd sizes and replacing trees in            
          or expanding the orchard.  Petitioner also attended a 1-day olive           
          growers convention and sought other related advice regarding                
          Omega’s farm operation.  Finally, petitioner met with the                   
          accountant to discuss the financial statements and the high                 
          expenses and paucity of income.  In spite of the advice sought              
          and/or received, nothing was done to change the farming activity            
          of Omega.  Although petitioner testified that he spent extensive            
          time engaged in Omega’s farming activity, there is little in the            






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