- 2 -
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6653(a)(1)
1986 $1,575.26 $78.86 1
--
1988 6,649.00 -- -- $332.45
1 Plus 50 percent of the interest payable under sec.
6601 with respect to the portion of the underpayment which
is attributable to negligence.
All section references are to the Internal Revenue Code as
in effect during the years in issue. Respondent also
determined the following deficiencies in, additions to, and
penalty on petitioner Kenneth E. Perry's separate Federal
income tax for the years in issue:
Additions to Tax Penalty
Sec. Sec.
Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) Sec. 6662
1987 $3,920 $196 1
--
1989 4,020 -- -- $804
1990 825 -- -- 165
1991 1,367 -- -- 273
1 Plus 50 percent of the interest payable under sec.
6601 with respect to the portion of the underpayment which
is attributable to negligence.
After concessions, the issues remaining for decision
are: (1) Whether petitioners' horse breeding and boarding
activity during 1986 and 1988 was an "activity not engaged
in for profit" within the meaning of section 183; (2)
whether petitioner Kenneth E. Perry's horse breeding and
boarding activity during 1987, 1989, 1990, and 1991 was an
"activity not engaged in for profit" within the meaning of
section 183; (3) whether petitioners are liable for the
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