Robert and Karen O'Connor - Page 17




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          record to corroborate his testimony or to show that his efforts             
          were directed at improving profitability.  In that regard, it is            
          noted that petitioners lived on the property.  In addition, as              
          argued by respondent, petitioner’s efforts in operating a                   
          successful recycling business limited the time available for                
          petitioner to work on the farming activity.                                 
               In this case there was no possibility for increase in the              
          value of the land inuring to Omega because it was a lessee.  In             
          addition, there was no expectation that any of the depreciable              
          property used in the farming operation would increase in value.             
          Petitioners also argue that their farm was in existence for only            
          2 years before the years in issue and therefore it was expected             
          that losses would be sustained for a reasonable period under the            
          circumstances.  Petitioners’ argument has little merit.  From               
          1990 through 1995, Omega incurred expenditures totaling $833,564            
          in the farm activity.  During the 3 years under consideration,              
          Omega’s expenditures totaled $438,663.  Accordingly, expenditures           
          were increasing rather than abating.  In sharp contrast, over the           
          farm activity’s 6-year existence, farm activity receipts totaled            















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