- 2 - The issues remaining for decision are: (1) Was the drawing that petitioner sold during 1989 "property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business" within the meaning of section 1221(1)? We hold that it was not, and we further hold that the gain that petitioner realized from the sale of that drawing is long-term capital gain.2 (2) Did petitioner engage in his horse activity during 1989, 1990, and 1991 and his cattle activity during 1990 and 1991 with the objective of making a profit within the meaning of section 183? We hold that he did not. (3) Is petitioner liable for 1989 and 1990 for the addition to tax under section 6651(a)(1)? We hold that he is not for 1989 and that he is for 1990 to the extent stated herein. (4) Is petitioner liable for 1989, 1990, and 1991 for the accuracy-related penalty under section 6662(a)? We hold that he is to the extent stated herein. 2 The parties agree that the Court's holding on the character- ization of petitioner's gain from that sale will be dispositive of the remaining issues presented under secs. 404(h)(1)(C) and 4972(a).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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