- 2 - 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.Page: Previous 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