- 43 - 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.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43
Last modified: May 25, 2011