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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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