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saw the first two pages only of the tax returns; thus, she was
not afforded the opportunity to review the Schedules F listing
the income and expenses attributable to the farming activity.
Petitioner also testified that she trusted Mr. Rowe when she
signed the tax returns because he told her the returns were
correct, and he assured her he had appropriate records.24
The evidence in the record indicates that Mr. Rowe
controlled all aspects of the farming activity, and he conducted
the activity without any assistance from petitioner. He
testified that he did not consult with petitioner before making
decisions concerning the farming activity, and he did not provide
her with any information about the activity. In fact, Mr. Rowe
testified that he felt that he was operating the horse activity
as a business. He also testified that he started the fish
activity in order to make the farming activity a more viable
business. The testimony of Mr. Danley and the Shortinos, as well
as the testimony and affidavit of Mr. Murray, all indicates that
Mr. Rowe acted as if he was engaged in the farming activity for
profit. There is no evidence that Mr. Rowe acted in such a
manner that would cause petitioner to know or believe that Mr.
Rowe was not engaged in the farming activity for profit.
24Petitioner testified that she did not know whether
parentheses around a number on a tax return indicated a loss or a
profit.
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