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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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