T.C. Memo. 1999-372
UNITED STATES TAX COURT
RALPH E. WESINGER, JR. AND CATHERINE R. WESINGER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 17610-97, 12694-98. Filed November 8, 1999.
Ps deducted losses sustained in their cattle-
ranching and aircraft-rental operations. R disallowed
these deductions on the grounds that the ranching and
rental activities were not engaged in for profit within
the meaning of sec. 183, I.R.C., and also assessed
accuracy-related penalties under sec. 6662, I.R.C.
Held: On the facts, the cattle-ranching and
aircraft-rental activities were not engaged in with a
profit objective, and Ps are not entitled to deduct the
losses therefrom.
Held, further, Ps failed to establish that they
exercised reasonable care in deducting such losses and
are thus liable for accuracy-related penalties based on
negligence. R’s determinations are sustained.
Steven J. Roth, for petitioners.
Andrew R. Moore and Caroline Tso Chen, for respondent.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011