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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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Last modified: May 25, 2011