-18- We find that Mr. Lamb’s tuna fishing activity was an activity engaged in for profit within the meaning of section 183(c). Petitioners’ deduction of the losses associated with this activity is, therefore, not subject to the limitations imposed by section 183(b). It follows that the penalty provisions of section 6662(a) do not apply. Decision will be entered for petitioners. 6(...continued) there[,] and I hadn’t seen any fish.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011