Case: U.S. Tax Court Upholds Farming Activity Not for Profit Ruling Amid Chevron Deference Overhaul (T.C. Memo)

The U.S. Tax Court held that the Taxpayer’s farming activity was not engaged in for profit, affirming its prior decision after reconsidering the case in light of the Supreme Court’s overruling of Chevron deference. Taxpayer, a partnership focused on ecotourism through hunting and fishing packages, challenged the validity of Treasury Regulations §1.183-1 and §1.183-2(b). The court found the farming and real estate activities to be separate, based on their interrelationships and management structures. The Tax Court held that even if the challenged regulations were invalid, the outcome would remain unchanged because: (1) determining whether undertakings constitute one or multiple activities ...