Morgan L.Lucid and Mary J. Lucid - Page 2

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          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.                                             




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