- 21 - Deductions Income Derived Attributable Year From Farming To Farming Net Gain (Loss) 1990 $3,737 $58,263 ($54,526) 1991 25,294 73,053 (47,759) 1992 17,705 95,714 (78,009) 1993 34,887 123,130 (88,243) 1994 40,914 94,893 (53,979) 1995 22,710 91,485 (68,775) Since petitioners’ income derived from farming did not exceed the deductions attributable thereto in any of the years in issue, their farming activity--i.e., the Maple Row cattle activity--must be treated as a separate activity from the holding of land, in accordance with section 1.183-1(d)(1), Income Tax Regs. Respondent concedes that petitioners’ separate activity of holding land was an investment activity for which the allocable expenses are deductible. (See supra note 8.) It therefore remains for us to decide whether petitioners’ separate activity of farming (i.e., as disaggregated under section 1.183-1(d)(1), Income Tax Regs., from the activity of holding land) was an activity not engaged in for profit within the meaning of section 183. B. Application of Section 183 to Cattle Activity Section 183(c) defines an activity not engaged in for profit as “any activity other than one with respect to which deductions are allowable for the taxable year under section 162 or underPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011