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Deductions
Income Derived Attributable
Year From Farming To Farming Net Gain (Loss)
1990 $3,737 $58,264 ($54,527)
1991 25,294 73,053 (47,759)
1992 17,705 95,715 (78,010)
1993 34,887 123,130 (88,243)
1994 40,914 94,893 (53,979)
1995 22,710 91,484 (68,774)
For the 4 years immediately following the years in issue, if the
same adjustments are made to show the results of the Maple Row
cattle activity as a separate activity, those results are as
follows:
Deductions
Income Derived Attributable
Year From Farming To Farming Net Gain (Loss)
1996 $21,461 $92,211 ($70,750)
1997 39,987 97,164 (57,177)
1998 51,792 124,531 (72,739)
1999 34,901 115,654 (80,753)
Thus, petitioners have shown losses for the first 6 years of
Maple Row’s operations (the years in issue), as well as the next
4 years.
Petitioners point out that courts have recognized a startup
period with respect to breeding activities that is longer than
the period associated with other activities, and argue that their
losses have been incurred during a startup period. See, e.g.,
Engdahl v. Commissioner, 72 T.C. at 669 (startup phase between 5
to 10 years for horse-breeding activity); Fields v. Commissioner,
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