-2- that Patrick F. Sheehy paid in 1991 to acquire interests in thoroughbred racehorses,1 and (2) whether petitioners are liable for the section 6662(a) accuracy-related penalty for 1991. All section references are to the Internal Revenue Code for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Some of the facts have been stipulated and are found accordingly. The stipulation of facts and the attached exhibits are incorporated herein by this reference. FINDINGS OF FACT At the time they filed their petition, petitioners Patrick F. and Arlene Gwon Sheehy, husband and wife, resided in Newport Beach, California. They timely filed their 1991 Federal income tax return. Background Patrick F. Sheehy (petitioner) is a medical doctor who specializes in oncology and hematology. He is also engaged in the business of developing champion racehorses. Mrs. Sheehy is a research ophthalmologist. Super Horse, Inc. During the year in issue, Super Horse, Inc. (Super Horse) purchased thoroughbred racehorses and sold interests in these horses to investors. Super Horse assisted individuals in 1 In the notice of deficiency, respondent allowed petitioners $12,675 as a depreciation deduction in lieu of the claimed $165,000 deduction for research and development expenses.Page: Previous 1 2 3 4 5 6 7 Next
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