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Petitioner did not seek expert advice about how to operate a
tree farm for profit. Sometime before 1990, he asked neighbors
who had botany degrees for advice on how to grow trees.
Petitioner attended several agricultural seminars: a fish
raising seminar in 1992, evergreen seminars in 1995 and 1997, a
tree pruning seminar in 1997, and a nursery short course at Ohio
State University in 1998.
Petitioners earned an unspecified amount of income from 1984
or 1985 to 1990 by allowing people to use their land to hunt and
to practice for competitions with their dogs. Petitioners also
tried to grow strawberries and grapes on their land and to raise
fish.
C. Petitioners’ Tax Returns
Petitioners reported on Schedules F, Profit or Loss From
Farming, attached to their tax returns for 1993 to 1998 that they
operated a tree farm. Petitioners reported the following amounts
of nonfarm income (i.e., wages, pension, interest, and taxable
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