- 2 - Accuracy- Related Additions to Tax Penalty Sec. Sec. 6653(a)(1)/ Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661 6662(a) 1987 $440,539 --- $22,027 * $110,135 --- 1988 202,360 --- 10,118 --- 50,590 --- 1989 215,930 $7,845 --- --- --- $43,186 * 50 percent of interest due on portion of underpayment attributable to negligence. In an Amendment to Answer, respondent increased the deficiency, addition to tax, and accuracy-related penalty for 1989 to $404,418, $17,269, and $80,883, respectively. The primary issues for decision are: (1) Whether, during the years in issue, petitioners' ownership and management of a timber farm property near Coos Bay, Oregon, constituted a trade or business activity entered into for profit, as petitioners contend, or a personal, nonbusiness, not-for-profit activity, as respondent contends; (2) whether petitioners' investment in property in Tahiti constituted a for-profit investment under section 212; (3) the deductibility under section 162 or section 212 of expenses relating to petitioners' use of a Lear jet to travel, among other places, to their Oregon timber farm property and to their property in Tahiti; and (4) to what extent expenses of petitioners' residence in Orange, California, qualify as home office expenses under section 280A. Various additional and alternative issues are also for decision (e.g., if petitioners' timber farm constitutes a for-profit trade or business activity,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