- 2 - Sec. 6662 Year Deficiency Penalty 1991 $11,611 $2,322.20 1992 16,818 3,363.60 Petitioners owned an antique store during the years in issue. Petitioners also owned a 52-acre farm on which they bred and trained quarter horses and held three rodeos during the years in issue. Respondent concedes that petitioners operated the rodeos for profit. In 1992, petitioners discontinued the horse and rodeo undertakings1 and began to operate a craft fair. After concessions, the issues for decision are: 1. Whether petitioners operated their antique store for profit in 1991 and 1992. We hold that they did not. 2. Whether petitioners operated the horse and rodeo undertakings as one activity in 1991 and 1992. We hold that they did. 3. Whether petitioners operated their horse and rodeo activity for profit in 1991 and 1992. We hold that they did. 4. Whether petitioners are liable for the accuracy-related penalty for negligence under section 6662 for 1991 and 1992. We hold that they are to the extent discussed below. 1 For purposes of sec. 183, two or more "undertakings" may be one "activity". Sec. 1.183-1(d)(1), Income Tax Regs. We refer to horse and rodeo "undertakings" because one of the issues in dispute is whether they were one activity.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011