Question: In Gary M . Schwarz et al . v . Commissioner, how did the U . S . Tax Court decide whether farming and holding

In Gary M. Schwarz et al. v. Commissioner, how did the U.S. Tax Court decide whether farming and holding land could be considered a single activity?
It referenced a test in the regulations that states its a single activity only if the farming activity reduces the net cost of carrying the land for its appreciation in value.
It examined the facts and circumstances to determine that farming and holding the land were inextricable.
It relied on the regulations, which states that activities can be treated as one when the IRS approves it.
It created a new test that states its a single activity only if the income derived from farming is less than the deductions attributable to the farming activity that are not directly attributable to the holding of the land.

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