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