-2-
1990 $9,560 $1,288
1991 6,561 878
The issues for decision are: (1) Whether petitioner Derril
O. Lamb’s tuna fishing activity was engaged in for profit within
the meaning of section 183;1 and, if not, (2) whether petitioners
are liable for accuracy-related penalties pursuant to section
6662(a) for negligence or substantial disregard of rules or
regulations.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Bowdoinham, Maine, at the time they filed their petition.
Mr. Lamb’s Tuna Fishing Activity
Petitioner Derril Lamb was born in 1925. Mr. Lamb began
harpooning tuna in 1958 when he constructed his own fishing boat
and learned how to harpoon from the most successful and
experienced fishermen on Bailey Island in Maine. From 1958
through 1960, Mr. Lamb harpooned 4, 8, and 16 tuna, respectively.
Beginning in 1961 and continuing for a number of years
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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