George R. and Barbara H. Burrus - Page 43

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          on which they conducted their cattle activity.17  With respect to           
          those portions, we find that petitioners had reasonable cause for           
          the underpayment.  We have found that petitioners conducted their           
          cattle activity with the requisite profit motive to avoid the               
          restrictions of section 183.  In these circumstances, their                 
          failure to adhere to the precise requirements of the regulations            
          requiring the treatment of farming and landholding as separate              
          activities does not, in our view, reflect a lack of effort to               
          assess their proper tax liability.                                          
               As for any remaining portions of the underpayments for the             
          years in issue, such as those attributable to petitioners’                  
          failure to substantiate claimed deductions, petitioners have not            
          addressed the issue, and we accordingly sustain respondent’s                
          determinations.                                                             
               In light of the parties’ concessions and the foregoing,                


                                                  Decision will be entered            
                                             under Rule 155.                          







               17 For example, underpayments may exist as a result of the             
          limitations imposed by sec. 163(d) on the mortgage interest                 
          deductions claimed by petitioners on Schedules F.                           




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