Rhett Rance Smith and Alice Avila Smith, et al. - Page 67




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               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 the              








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