Hoelscher v. Comr., T.C. Memo. 2013-236

(petitioners determined to have engaged in ranching activity without requisite profit intent - losses denied; gross income of $195,473 from activity and expenses of $2,826,336; no meaningful action taken to reduce expenses or increase income; court did not believe ranch acquired to profit from increase in value; court noted that enhanced value as intent to profit is useful only if income from activity exceeds deductions from ranching activity that are not attributable to holding the land).