Kenneth E. Perry and Mary A. Hofer - Page 3

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             additions to tax for negligence prescribed by sections                   
             6653(a)(1)(A) and (B) and 6653(a)(1) with respect to their               
             1986 and 1988 returns; (4) whether petitioner Kenneth E.                 
             Perry is liable for the additions to tax for negligence                  
             prescribed by section 6653(a)(1)(A) and (B) with respect to              
             his 1987 return; and (5) whether petitioner Kenneth E.                   
             Perry is liable for the accuracy-related penalty prescribed              
             by section 6662 with respect to his 1989, 1990, and 1991                 
             returns.                                                                 
                                  FINDINGS OF FACT                                    
                  Some of the facts have been stipulated and are so                   
             found.  The stipulation of facts and attached exhibits are               
             incorporated herein by this reference.  Petitioners are                  
             husband and wife who filed joint Federal income tax returns              
             for 1986 and 1988.  Petitioner Kenneth E. Perry filed                    
             separate Federal income tax returns for 1987, 1989, 1990,                
             and 1991.  At the time they filed their petition in this                 
             case, petitioners resided in Brookville, Ohio.                           
                  Petitioners were both raised on family farms, and                   
             both have been around horses most of their lives.                        
             Mr. Perry learned to break and care for horses when he                   
             was 10 to 12 years old and was involved in purchasing,                   
             breeding, training, and selling horses with his father and               
             brother for over 20 years prior to 1986.  Ms. Hofer also                 
             learned to break and care for horses at a very young age                 




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