Robert E. and Carloyn S. Holmes - Page 2

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                                 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 are                  





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