- 68 - 1999 tax year reflects that other than depreciation and repairs of the property, most of the expenditures were for the dog breeding activity, including dog training and showing. No expenses were claimed that appeared to relate directly to the cow and dairy farm activity. Likewise, for the 2000 tax year most were for the dog breeding activity, and only a relatively small portion could have been connected with the cow and dairy farm activity. For 2001 two Schedules F were included, and the one labeled “Cattle Crops--Dog Breeding” contained substantially increased expenditures. Relatively large amounts were spent on items relating to cows such as feed and trucking expenses. The second Schedule F was labeled “Organic Dairy Farm” and contained claimed expenditures and depreciation totaling $98,470. These circumstances reflect that Zane did not begin to pursue the dairy farm idea until 2001. Any expenditures nominally connected with cows before 2001 would have, in any event, been considered startup expenditures (which are to be capitalized) and were incurred before the implementation of the plan to pursue the dairy farm. See Toth v. Commissioner, 128 T.C. 1, 4-6 (2007). Accordingly, we agree with respondent that Zane and Shannon are not entitled to claim any losses in connection with his cow activity before 2001. With respect to 2001, Zane had studied and researched the various types of cattle that could be bred. Zane recognized thatPage: Previous 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 NextLast modified: March 27, 2008