- 2 -
1991 4,908 1,049 982
1992 4,646 -- 929
Unless otherwise noted, all section references are to the
Internal Revenue Code (Code) as in effect for the years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
After concessions, the following issues remain for decision:
(1) Whether petitioner's photography activity constituted an
activity not engaged in for profit within the meaning of section
183 during the years in issue; (2) whether petitioner is liable
for the addition to tax for failure to file timely her 1990 and
1991 Federal income tax returns; and (3) whether petitioner is
liable for the accuracy-related penalty provided by section
6662(a) for the years in issue.
FINDINGS OF FACT
Some of the facts and certain exhibits have been stipulated
for trial pursuant to Rule 91.1 The stipulations of fact are
incorporated herein by reference and are found accordingly.
At the time the petition in the instant case was filed,
petitioner resided in Soquel, California.
During the years in issue, petitioner was employed full time
as an account clerk by the Santa Cruz Health Services Agency in
1 Respondent objected to admission of certain exhibits
pertaining to years subsequent to the years in issue on grounds
of materiality and relevance. We sustain respondent's objection.
Fed. R. Evid. 401. We note, however, that our decision in the
instant case would not be affected by admission of the exhibits
to which respondent has objected.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011