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effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioners’ Federal
income taxes of $2,417, $3,469, $4,236, and $3,276, and accuracy-
related penalties of $483.40, $693.80, $847.20, and $655.20 for
the taxable years 1996, 1997, 1998, and 1999.
The sole issue for decision is whether petitioner husband
(petitioner) engaged in certain activities for profit during each
of the years in issue.1 Respondent concedes the application of
the accuracy-related penalties in this case.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
West Salem, Wisconsin, on the date the petition was filed in this
case.
Petitioners filed a joint Federal income tax return for each
of the years in issue. With these returns, petitioners filed
Schedules C, Profit or Loss From Business, for several
activities. In 1996, petitioners filed a Schedule C which named
petitioner as the proprietor and listed “rental” as the principal
business. This schedule reflected the following loss:
1Petitioners also argue in their petition that petitioner
was “able to engage in a trade or business”, and that he was not
precluded from doing so by any medical disability. Petitioner’s
physical or mental ability to engage in a trade or business is
not being questioned in this case.
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