- 18 - Respondent cites several cases where we held that the taxpayer’s activities could not be aggregated and argues that those cases are analogous to the facts in this situation. In De Mendoza v. Commissioner, supra, the Court refused to aggregate the taxpayer’s farming/polo activity and his real estate law practice, despite the taxpayer’s position that one reason he began playing polo was to meet clients for his law firm. Based on the evidence, the Court concluded that the farm was formed and operated as a separate business, and the Court was not convinced that the taxpayer began the polo activity to generate legal business or that the activity materially benefited the taxpayer’s law practice. In Wilkinson v. Commissioner, T.C. Memo. 1996-39, we held that a plastic surgeon’s horse ranch activities and his medical practice were not interrelated business activities, despite the taxpayer’s claim that the publicity he derived from playing polo and hosting social gatherings helped him get patients for his cosmetic surgery practice. Id. In Zdun v. Commissioner, T.C. Memo. 1998-296, affd. without published opinion 229 F.3d 1161 (9th Cir. 2000), we held that a dentist’s organic apple orchard was not part of the same activity as his holistic dental practice even though the apples were sold to the dental practice’s patients at the office. We do not find any of the cases respondent relies on to be analogous to petitioner’s situation. None of the activities inPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: November 10, 2007