Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 14

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          vendors.  Because of their success in the fall of 1992,                     
          petitioners decided to hold their own fair, called the Great Gay,           
          Georgia, Marketplace, twice a year, when the Cotton Picking Fair            
          is held.                                                                    
          E.   Petitioners' Tax Returns                                               
               Petitioners reported the following gross receipts, losses,             
          and depreciation for 1991 and 1992:                                         
                    Gross          Losses (including                                  
          Year         receipts       depreciation)         Depreciation              
                                      Antiques                                        
          1991      $1,885              ($10,952)           $2,594                    
          1992           2,589          (9,830)             2,443                     
                                  Horses and Rodeos                                   
          1991      3,947               (40,746)                 4,426                
          1992      21,589              (44,600)                 8,146                
               Petitioners reported their horse and rodeo undertakings on             
          the same schedule in 1991 and 1992.  Petitioners had gross                  
          receipts from their fair in 1992 of about $3,020 with no expenses           
          or depreciation.                                                            
                                    II.  OPINION                                      
               Respondent concedes that petitioners operated the rodeos for           
          profit.  We must decide whether petitioners operated their                  
          antique store for profit in 1991 and 1992.  We must also decide             
          whether petitioners' horse and rodeo undertakings were one                  
          activity, and if so, whether they operated that activity for                
          profit in 1991 and 1992.  Finally, we must decide whether                   
          petitioners are liable for the accuracy-related penalty for                 





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