T.C. Memo. 1996-68
UNITED STATES TAX COURT
CHARLES A. BALLARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10333-94. Filed February 20, 1996.
B is an S corporation involved in the business of
yacht chartering. P, the sole shareholder of B,
claimed losses passed through from B. R disallowed P’s
losses on the ground that B’s activity was not engaged
in for profit.
1. Held: B’s yacht chartering activity was not
engaged in for profit within the meaning of sec. 183,
I.R.C.
2. Held, further, sec. 6653(a), I.R.C., addition
to tax is not sustained against P.
3. Held, further, sec. 6661, I.R.C., addition to
tax is sustained against P.
James S. Kaplan, for petitioner.
Moira L. Sullivan and Paul T. Muniz, for respondent.
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