The taxpayer bought land in 2003 and started a farming operation at that time, later setting up a farm checking account and writing a business plan. The taxpayer originally started raising cattle, but later switched to growing hay and horse boarding, raising and training. The taxpayer also used some of the property as a vineyard. Ultimately, the farming operations generated losses that the defendant disallowed the taxpayer's Schedule F deduction. Based on the nine-factor analysis of I.R.C. Sec. 183, the court determined that the taxpayer was not engaged in the farming activity with the required profit intent. The defendant also added the 100 percent penalty for willful attempt to evade tax, but the court determined that the penalty did not apply due to lack of purposeful acts beyond mere negligence. However, the court did impose the substantial understatement penalty. Deboer v. Department of Revenue, No. TC-MD 140027N, 2014 Ore. Tax LEXIS 168 (Ore. Tax. Ct. Sept. 25, 2014).