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Joseph E. Machado
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) Sec. 6661
1988 $19,687 $4,441 $1,133 $4,922
Robert R. and Kerry S. Machado
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) Sec. 6661
1988 $19,576 $3,889 $1,422 $4,894
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1988, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
After settlement, the primary issues for decision in these
consolidated cases are whether petitioners Joseph E. Machado and
Robert R. Machado bred and raced horses for profit and whether
losses petitioners Joseph E. Machado and Robert R. Machado
realized from partnership investments are limited by the passive
activity loss provision of section 469.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time the petitions were filed, petitioners Joseph E., Robert
R., and Kerry S. Machado resided in Long Beach, California.
Hereinafter, references to petitioners will be to petitioners
Joseph and Robert Machado.
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Last modified: May 25, 2011