- 67 - In this instance, there was no organizational or economic interrelationship between the two activities. Other than the reporting of the expenses of both on the same Schedule F, the activities were geographically and financially independent. No business purpose was expressed other than Zane’s ability to use his knowledge of dog breeding in cow breeding. The use of that experience and knowledge by Zane is not, per se, a business purpose and did not result in any economy of scale or symbiosis between the two activities. The cow and dairy farm activity was a separate pursuit. We treat the dog breeding activity and the cow and dairy farm activity as separate for purposes of our section 183 analysis. Beginning in 1998, Zane claimed losses on Schedule F from his cow and dairy farm activity which he reported along with those of his dog breeding activity and described as “cattle crops--dog breeding”. Subsequently, in 2001 he described the activity as “organic dairy farm” on his Schedule F. Respondent contends that Zane did not effectively enter into the cow and dairy farm activity until 2001, whereas Zane contends that the early activity involving the cattle was preliminary to and an integral part of the expansion of that activity in 2001. In 1998, Zane purchased a 400-acre farm, (Goose Hill), in upstate New York where he also built his home. His Schedule F for thePage: Previous 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 NextLast modified: March 27, 2008