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the assets of both undertakings; (h) whether the taxpayer used
the same accountant for the undertakings; and (i) the degree to
which the undertakings shared books and records. See Keanini v.
Commissioner, 94 T.C. 41, 46 (1990); Tobin v. Commissioner, T.C.
Memo. 1999-328; Estate of Brockenbrough v. Commissioner, T.C.
Memo. 1998-454; Hoyle v. Commissioner, T.C. Memo. 1994-592; De
Mendoza v. Commissioner, T.C. Memo. 1994-314; Scheidt v.
Commissioner, T.C. Memo. 1992-9.
We find it is appropriate to treat petitioner’s various
farming undertakings as one activity. The undertakings are all
agricultural and were performed at the family farm. The
undertakings all demonstrate petitioner’s efforts to generate
revenue from the family farm. The mature timber harvesting and
the haying generated current revenue while the tree-planting may
generate future revenue. The undertakings were not formed as
separate businesses. The tree-planting undertaking benefited
from the mature timber harvesting undertaking as mature timber
harvesting made additional land available for tree-planting.
Petitioner managed all the undertakings. Petitioner himself was
the accountant for all the undertakings. Finally, petitioner
used one checking account to pay the expenses of and to deposit
the revenues from the various undertakings.
After reviewing these factors and the facts and
circumstances of this case, we find that petitioner’s tree-
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