- 2 -
S.K. Johnston III and Julie N. Boyle, f.k.a., Julie N. Johnston,
docket No. 16668-942:
Additions to Tax
Year Deficiency Sec. 6661
1987 $15,877.43 $4,969.00
1988 16,890.08 4,223.00
1989 12,026.80 -
S.K. Johnston, Jr., docket No. 16669-94:
Additions to Tax
Year Deficiency Sec. 6653(a)(1) Sec. 6661
1988 $174,164.19 $8,708.21 $43,609.00
S.K. Johnston, Jr., and Gillian S. Johnston, docket No. 16670-94:
Additions to Tax and Penalty
Year Deficiency Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B) Sec. 6661 Sec. 6662
1987 $222,349.65 $11,117.48 * $55,587.00 -
1989 312,431.41 - - - $62,486.28
* 50 percent of the interest due on $21,235.83.
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
2 The only issue that involves S.K. Johnston III and Julie N.
Boyle, f.k.a. Julie N. Johnston is whether Bendabout Polo Sales
and Management Co. (BPS) was an activity engaged in for profit.
BPS, a partnership owned 75 percent by S.K. Johnston, Jr. and 25
percent by his son, S.K. Johnston III began operations on June 1,
1986, as a polo horse sales business.
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