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years 1980 and 1981, respondent determined deficiencies in Hans
Hammann's Federal income taxes and additions to tax as follows:
Additions To Tax
Year Deficiency Sec. 6653(a) Sec. 6653(a)(1) Sec.6653(a)(2)
1980 $2,987 $149.35 --- ---
1981 608 --- $30.40 1
1 This amount is 50 percent of the interest due on any part of the
deficiency due to negligence.
Respondent also determined deficiencies in petitioners'
1983, 1984, and 1985 Federal income taxes and additions to tax as
follows:
Additions To Tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1983 $10,150 $508 1 $2,538
1984 11,739 587 1 2,935
1985 14,307 715 1 3,577
1 This amount is 50 percent of the interest due on any part of the
deficiency due to negligence.
Respondent further determined that the increased rate of
interest imposed by section 6621(c) was applicable for each year
in issue.
The issues for decision are: (1) Whether for the years
1983, 1984, and 1985 Hans Hammann conducted a charter boat
service with the requisite profit motive to allow for deductions
under section 162(a), and, if so, whether petitioners can
substantiate the deductions claimed in connection with the
charter boat service for the years 1984 and 1985; (2) whether the
charter boat service gave rise to investment tax credits for the
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