Walter L. Medlin - Page 17

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          matter.  We sustain respondent’s determination of the allowable             
          mortgage interest expenses.                                                 
               3.  Orange Grove, Cattle, and Ferrari Activities                       
                                  FINDINGS OF FACT                                    
               Petitioner had an orange grove of approximately 800 trees              
          near his personal residence, which covered approximately 17 to 18           
          acres.  When petitioner moved to his personal residence in or               
          about 1981, the orange grove was old with at least a portion of             
          it having been planted in the 1920s.  Petitioner was not in the             
          growing business, and he allowed the orange grove to deteriorate.           
               After a bad freeze in 1985, petitioner let the orange grove            
          go for a year without spraying it (without putting any herbicide            
          or fertilizer on the trees).  Petitioner replaced a considerable            
          number of old trees and dead trees with 690 new trees.  The                 
          orange grove had an irrigation system which needed repairs, and             
          the orange grove required fertilizer and herbicide treatment.               
          Petitioner paid $10,000 on June 22, 1987, and $6,371.53 on June             
          1, 1988, to Irrigation Engineers for certain irrigation work done           
          on petitioner’s orange grove.  Petitioner did not maintain any              
          books or records for the orange grove, except for his checkbook.            
          Petitioner has never made a profit from selling oranges.                    
               Petitioner also owned cattle during the tax years at issue.            
          Petitioner was advised by Michael Partin, a rancher, that the               








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