Robert Irwin Solomon - Page 3

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               Respondent determined a deficiency of $4,060 for                       
          petitioner’s 1995 Federal income tax.  The issue before the Court           
          is whether expenses incurred by petitioner in purchasing a                  
          tractor and a fuel tank are deductible under section 179.                   
          Petitioner resided in Williamsburg, Virginia, at the time the               
          petition was filed.                                                         
               Petitioner is a full-time practicing neurologist with                  
          medical offices in Williamsburg and Newport News, Virginia.                 
          Petitioner purchased 49 acres of land in 1986.  Petitioner’s                
          putative farming activity is conducted on 6 acres.  Petitioner              
          cultivated the 6 acres for hay and, during 1995, rented the land            
          for $150 to a farmer who harvested the hay.  The remaining                  
          acreage consisted of 39 acres of forest, 2 acres of open land,              
          and 2 acres associated with a house that was petitioner’s                   
          residence during 1995.                                                      
               Petitioner maintained the remainder of the property.  In               
          1995, petitioner purchased a tractor for $11,900 and a 280-gallon           
          fuel tank.  Petitioner elected to “expense” these items under               
          section 179.  Respondent determined that under section 183                  
          petitioner was not engaged in his farming activity for profit,              
          and, therefore, disallowed the deduction.                                   
               We do not believe that it is necessary to engage in an                 
          extended exegesis on the agricultural economics of petitioner’s             
          farming activity to decide this issue.  Relevant here, section              

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