Holdner, et al. v. Comr., T.C. Memo. 2010-175

(father-son farming operation determined to be partnership for tax purposes and not a joint venture between two individual proprietorships; no formal written partnership agreement; while parties shared farm income equally, most expenses allocated to father resulting in net losses on father's personal return even though father had high non-farm income from CPA practice; no partnership return filed; farm bank account created; insurance policy purchased for farming operation; farming operation registered with state as a partnership; accuracy-related penalty upheld against father).