- 3 -
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
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