Frank K. B. Wheeler - Page 1

















                                 T.C. Memo. 1999-56                                   


                               UNITED STATES TAX COURT                                


                          FRANK K.B. WHEELER, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8269-97.                 Filed February 26, 1999.           


                    During 1993, 1994, and 1995, P conducted a videotape              
               activity.  P bought significant amounts of equipment,                  
               claimed large deductions (primarily depreciation), and                 
               generated little receipts during the years in issue.                   
                    1.   Held:  On the facts, P’s activity was not engaged            
               in for profit; deductions in excess of income from the                 
               activity were properly disallowed.  Sec. 183, I.R.C. 1986.             
                    2.   Held, further, P is liable for negligence                    
               additions to tax.  Sec. 6662, I.R.C. 1986.                             

               Barbara Morlan DeCaro, for petitioner.                                 
               Steven L. Walker, 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