Key legal question
Whether the agricultural business was a self-employed activity with profit motive under direct federal tax law.
Extracted holding
The farm was not run with sufficient profit motive; it amounted to a continuing loss source rather than a deductible self-employed activity.
Extracted reasoning
Although the operation could objectively be profitable, it had produced persistent losses for years. Continued operation despite long-term unprofitability showed lack of earnings intent; lack of subsidies did not change this.