- 14 - 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 forPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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