Steven Carl Akerson - Page 2

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                                                             Penalty                                     
                      Year                Deficiency         Sec. 6662(a)                                
                        1989               $3,771            $754                                        
                        1990               32,683            6,537                                       
            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 for decision are:  (1) Whether petitioner's                                 
            resort operations constituted an activity not engaged in for                                 
            profit within the meaning of section 183 and (2) whether                                     
            petitioner is subject to the section 6662(a) accuracy-related                                
            penalty for 1989 and 1990.                                                                   
                                          FINDINGS OF FACT                                               
                  Some facts have been stipulated and are so found.  The                                 
            stipulation of facts, with attached exhibits, is incorporated                                
            herein by this reference.                                                                    
                  At the time of filing the petition, petitioner resided in                              
            Puntarenas, Costa Rica.                                                                      
            Background                                                                                   
                  Petitioner is a physicist who is dedicated to the use and                              
            promotion of solar energy.1  In 1980 and 1981, petitioner                                    
            chartered sailboats and installed solar equipment in Mexico and                              


            1     Petitioner holds United States patents on several inverter                             
            designs.  Inverters change DC electricity to AC electricity.                                 
            Solar energy panels produce DC electricity.  Most homes use AC                               
            electricity.                                                                                 




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