- 2 - Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6653(a)(1) 1987 $10,571.00 $528.55 1 -- 1988 15,270.51 -- -- $763.53 1989 12,412.00 -- -- -- 1990 6,107.00 -- -- -- 1991 15,681.00 -- -- -- 1Fifty percent of the interest computed under sec. 6601 with respect to the portion of the underpayment which is attributable to negligence. Unless otherwise stated, all section references are to the Internal Revenue Code as in effect during the years in issue. After concessions, the issues remaining for decision are: (1) Whether petitioners' farming activity during the years in issue was an "activity not engaged in for profit" within the meaning of section 183; and (2) whether petitioners are liable for the additions to tax for negligence prescribed by section 6653(a)(1)(A) and (B) with respect to their 1987 return, and the addition to tax for negligence prescribed by section 6653(a)(1) with respect to their 1988 return. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts, first supplement to stipulation of facts, and exhibits attached to each are incorporated herein by this reference. Petitioners arePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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