Derril O. Lamb, Jr. and Joyce Lamb - Page 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                                   

                                           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.                                                                       

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

Last modified: May 25, 2011