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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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