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After respondent's acceptance of petitioner's tax returns, the
resulting tax deficiencies and additions to tax in dispute are as
follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1988 --- --- ---
1989 --- --- ---
1990 1$12,485 $3,319 $779
1991 14,178 1,045 241
1992 135,031 8,903 1,523
1993 128,390 5,656 911
1 These amounts do not take into account prepayment credits
in the amounts of $816, $783, $792, $2, $580, and $801 for tax
years 1988, 1989, 1990, 1991, 1992, and 1993, respectively.
Following concessions,1 the sole unagreed matter concerns
petitioner's entitlement to losses sustained from certain cattle-
ranching business activities. In this regard, we must determine
whether petitioner conducted these cattle-ranching business
activities as a sole proprietor or through Spirit Horse Ranch,
Inc., during the years at issue.2
All section references are to the Internal Revenue Code as in
effect for the years in issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
1 Petitioner agrees that except for the disallowance of
the Schedule F losses, respondent's income adjustments in the
notices of deficiency are correct.
2 At trial, we found that the cattle-ranching activities
were operated for profit.
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