Rodney W. Taras and Linda K. Taras - Page 2

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               After concessions,1 the issues remaining for decision are:             
          (1) Whether petitioners' horse racing and breeding activity                 
          during 1987, 1988, 1989, and 1990 was an activity "not engaged in           
          for profit" within the meaning of section 183; and (2) whether              
          petitioners are liable for additions to tax pursuant to section             
          6651.2                                                                      

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and second stipulation of facts are                
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioners resided in Walnutport, Pennsylvania.                 
               During the years at issue, Ms. Taras was employed as a full-           
          time secretary in the accounting department at Bethlehem Steel              
          Corp. (Bethlehem).  Ms. Taras worked 40 hours per week at                   
          Bethlehem.  On their 1987, 1988, 1989, and 1990 Federal joint               
          income tax returns, petitioners reported gross income from                  
          Bethlehem in the amounts of $26,690, $27,458, $29,576, and                  
          $31,804, respectively.                                                      




               1Petitioners concede that the notice of deficiency for 1987            
          improperly allowed a gambling loss deduction in the amount of               
          $3,701, thereby erroneously reducing taxable income by $3,701.              
               2Unless 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.                                                                  



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