- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011