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two or more undertakings as one activity unless the
characterization is artificial or unreasonable. Id.
We have considered these and other factors in determining
whether the taxpayer's characterization is unreasonable. The
other factors so considered include: (a) Whether the
undertakings are conducted at the same place; (b) whether the
undertakings were part of the taxpayer's efforts to find sources
of revenue from his or her land; (c) whether the undertakings
were formed as separate activities; (d) whether one undertaking
benefited from the other; (e) whether the taxpayer used one
undertaking to advertise the other; (f) the degree to which the
undertakings shared management; (g) the degree to which one
caretaker oversaw 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. Mitchell v. Commissioner, T.C. Memo. 2006-145 (citing
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 petitioner’s characterization of the equestrian and
design undertakings as a single activity for purposes of section
183 to be supported by the facts of this case. A close
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