Patrick F. and Arlene Gwon Sheehy - Page 2

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          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.                  





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