- 2 -
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6653(a)(1)
1987 $10,571.00 $528.55 1 --
1988 15,270.51 -- -- $763.53
1989 12,412.00 -- -- --
1990 6,107.00 -- -- --
1991 15,681.00 -- -- --
1Fifty percent of the interest computed under sec.
6601 with respect to the portion of the underpayment which
is attributable to negligence.
Unless otherwise stated, all section references are to the
Internal Revenue Code as in effect during the years in
issue. After concessions, the issues remaining for
decision are: (1) Whether petitioners' farming activity
during the years in issue was an "activity not engaged in
for profit" within the meaning of section 183; and (2)
whether petitioners are liable for the additions to tax for
negligence prescribed by section 6653(a)(1)(A) and (B) with
respect to their 1987 return, and the addition to tax for
negligence prescribed by section 6653(a)(1) with respect to
their 1988 return.
FINDINGS OF FACT
Some of the facts have been stipulated and are so
found. The stipulation of facts, first supplement to
stipulation of facts, and exhibits attached to each are
incorporated herein by this reference. Petitioners are
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