- 10 - D. One Activity or Two Respondent contends that petitioner operated two activities, a resort activity with no profit motive and a solar equipment activity with a profit motive. Because we find that petitioner engaged in the resort activity with a profit motive, it is not necessary for us to decide whether the solar equipment business was a separate activity. E. Conclusion Petitioner's activity of operating Playa de los Vivos was an activity engaged in for profit within the meaning of section 183(c). Accordingly, petitioner's expenses attributable to that activity are allowable as deductions. II. Negligence Respondent determined that petitioner is liable for the accuracy-related penalty prescribed by section 6662 with respect to 1989 and 1990. Because we have not sustained respondent's determination of tax deficiencies in petitioner's income tax for the years in issue, there is no basis for the imposition of the penalties determined by respondent. In light of the foregoing, Decision will be entered for petitioner.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011