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MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: This is an affected items proceeding arising
from a disallowed partnership loss claimed for 1992 by Timeshare
Breeding Service 1990-1, J.V. (TBS 90-1), a cattle partnership
organized, promoted, and operated by Walter J. Hoyt III (Hoyt).2
Petitioners participated in TBS 90-1, and they reported their
distributive share of its reported ordinary loss on their 1992
Federal income tax return. With respect to their reporting of
the disallowed loss, respondent determined that petitioners are
liable for 1992 for a $205.80 accuracy-related penalty under
section 6662(a) and a $10,926.80 accuracy-related penalty under
section 6662(h). Following petitioners’ concession that they are
liable for the accuracy-related penalty determined by respondent
under section 6662(a), we decide whether they are liable for the
accuracy-related penalty determined by respondent under section
6662(h). We hold they are.
FINDINGS OF FACT
The parties filed with the Court stipulations of fact and
accompanying exhibits. The stipulated facts are found
accordingly. Petitioners are husband and wife, and they resided
in Tinley Park, Illinois, when their petition was filed.
2 The Commissioner’s disallowance of this loss was upheld in
Durham Farms #1, J.V. v. Commissioner, T.C. Memo. 2000-159, affd.
59 Fed. Appx. 952 (9th Cir. 2003).
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Last modified: November 10, 2007