John A. Rowe and Donna L. Rowe - Page 47




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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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