[Verse 1]
Moldowan had a farming dream back in seventy-seven
Wanted to deduct his losses, thought he'd found his heaven
But the Tax Court said "hold on, we need to take a look"
At whether farming's really your main source by the book
[Chorus]
Chief source of income, that's the test we need to know
Three classes of farmers, here's how the losses go
Full-time gets full deduction, combination too
But part-time farmers get restricted, that's the rule for you
Moldowan, Moldowan, section thirty-one
Chief source test was born, but Craig would change what's done
[Verse 2]
Class one farmers make their living from the farming trade
Class two combines farming with another source that's made
But class three are the part-timers with a job somewhere
Their farming losses get restricted, taxpayers beware
[Chorus]
Chief source of income, that's the test we need to know
Three classes of farmers, here's how the losses go
Full-time gets full deduction, combination too
But part-time farmers get restricted, that's the rule for you
Moldowan, Moldowan, section thirty-one
Chief source test was born, but Craig would change what's done
[Bridge]
Nineteen seventy-seven Supreme Court made it clear
If farming's not your chief source, restrictions will appear
The combination test was narrow, hard to satisfy
Until Craig came along and made the standard less than high
[Verse 3]
For thirty-five long years this framework held its ground
Part-time farmers faced restrictions when their losses were found
But remember when you study this important case
That Craig in twenty-twelve put new rules in their place
[Chorus]
Chief source of income, that's the test we need to know
Three classes of farmers, here's how the losses go
Full-time gets full deduction, combination too
But part-time farmers get restricted, that's the rule for you
Moldowan, Moldowan, section thirty-one
Chief source test was born, but Craig would change what's done
[Outro]
So read Moldowan first to understand the frame
Then study Craig to see how the rules have changed the game
Two S-C-R five-eleven, that's the cite you need
Moldowan taught us farming loss, the foundational seed