Eugene J. Phillips and Barbara A. Phillips - Page 2

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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               The issues to be decided are as follows:                               
               1.  Whether petitioners engaged in a horse breeding activity           
          with an actual and honest profit objective; and                             
               2.  whether petitioners are liable for penalties on income             
          tax pursuant to section 6662.                                               
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated for trial pursuant to           
          Rule 91.  The parties' stipulations of fact are incorporated                
          herein by reference and are found as facts in the instant case.             
               At the time they filed their petition in the instant case,             
          petitioners Eugene J. Phillips (Mr. Phillips) and Barbara A.                
          Phillips (Mrs. Phillips) resided in Stuart, Virginia, at their              
          farm, known as Green Pines Farm.  Petitioners filed joint U.S.              
          Individual Income Tax Returns (Forms 1040) for each of the years            
          in issue.                                                                   
               During the years in issue, Mr. Phillips was employed as a              
          nurse anesthetist, and Mrs. Phillips was engaged in the rearing             
          and breeding of Arabian horses (Arabians) and quarter horses                
          (hereinafter horse activity) on petitioners' farm.  Besides her             
          involvement with the horse activity, Mrs. Phillips was not                  
          employed during the years in issue.                                         




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