- 2 - 1990 and 1991, respectively. The issues for our consideration are: (1) Whether, in 1990 and 1991, petitioners were engaged in an activity for profit pursuant to section 183(a); and (2) whether petitioners are liable for accuracy-related penalties under section 6662(a) for the 1990 and 1991 taxable years. FINDINGS OF FACT2 Petitioners resided in Fresno, California, at the time the petition in this case was filed. Morgan L. Lucid (petitioner husband) was a full-time plastic surgeon, and Mary J. Lucid (petitioner wife) was a full-time psychotherapist licensed in California until her retirement on June 30, 1986. Petitioner husband is an experienced sailor and served in the Navy during World War II. Petitioner husband has had navigation experience with a sextant and the Geographical Positioning System. He has taken courses in navigation, metal welding, and meteorology. Petitioner husband has also made engine, radar, and radio repairs, and was a certified scuba diver and licensed ham radio operator. Petitioner wife is an experienced sailor and has taken courses in meteorology, coastal navigation, ham radio, and first aid. Petitioner wife has also 1(...continued) issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 The parties' stipulation of facts and exhibits is incorporated by this reference.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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