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on the basis of comparable sales of farm land, and another farm
with 225 acres (Columbus Dairy) which was purchased in 2000 for
$500 to $600 per acre and is currently worth around $1,200 to
$1,500 per acre on the basis of comparable land sales.
Although we do not consider the land appreciation and the
cow and dairy farm activity as a single activity, we recognize
that Zane’s investment in the land and buildings also has the
potential for appreciation and profit. On that basis, we find
this factor to be favorable to Zane.
5. Taxpayer’s Success in Similar or Dissimilar Activities--
Zane operated the dog breeding activity at a loss before entering
the cow and dairy farm activity. Although Zane was not
financially successful in the dog breeding activity, he was
successful in gaining expertise in animal husbandry and related
topics involving the care and breeding of animals. Beneco is a
successful business operated by Zane and his family. We discern
that Zane has employed some of the success of other endeavors in
his cow activity and, accordingly, this factor is favorable to
Zane.
6. The Activity’s History of Income and/or Losses--By the
end of 2001, Zane’s accumulated losses from the cow activity
approached $153,000. Although the total losses had increased to
approximately $307,000 by 2003, the last year for which a
Schedule F was available, the potential for increased revenues
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