Hans H. and Cheryl E. Hammann - Page 2

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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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