- 106 - 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 thePage: Previous 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 Next
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