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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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Last modified: May 25, 2011