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Mr. Hendricks and Mr. Angeli testified at trial that the
risks associated with the substantial farming enterprise with
which Mr. Hendricks was engaged at the time were what motivated
the transfer of the remaining condominiums. Petitioner was not
involved in the farming enterprise, and the Hendrickses wanted to
protect their investment in the remaining condominiums because
they constituted the Hendrickses’ only financial resource for
their retirement outside of Social Security. Furthermore,
despite the lack of success with the farming enterprise, Mr.
Hendricks paid all of his debts from the farming enterprise.
There is nothing in the record to indicate that the
Hendrickses’ standard of living increased in comparison to their
standard of living in prior years. Their lifestyle was not
lavish, and they made no unusual expenditures. We find that
petitioner did not significantly benefit from the deduction
attributable to Mr. Hendricks’s investment in Boulder Oil and
Gas. See Hayman v. Commissioner, supra; Jonson v. Commissioner,
118 T.C. 106 (2002), affd. 353 F.3d 1181 (10th Cir. 2003).
As retirees, the Hendrickses rely on the Social Security
checks they receive monthly and depend upon the rents from the
remaining condominiums for income. Their current monthly living
expenses exceed their income by about $1,100. They are able to
meet their living expenses only through financial assistance from
their children. We conclude that petitioner would experience
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