Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 21

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          This factor favors respondent.                                              
               10. Petitioners' Other Contention                                      
               Petitioners point out that petitioners were audited for                
          1988, and that respondent's agents who conducted that audit did             
          not tell petitioners that they thought petitioners lacked a                 
          profit motive for their antique activity.  Petitioners contend              
          that this shows that they had a profit motive for their antique             
          activity in 1991 and 1992.  We disagree.  The Commissioner's                
          failure to raise an issue in a prior audit does not estop the               
          Commissioner from raising it in an audit for a later year.  See             
          Knights of Columbus Council No. 3660 v. United States, 783 F.2d             
          69, 73 (7th Cir. 1986); Hawkins v. Commissioner, 713 F.2d 347,              
          351-352 (8th Cir. 1983), affg. T.C. Memo. 1982-451.                         
               11. Conclusion                                                         
               We conclude that petitioners did not conduct their antique             
          activity for profit in 1991 and 1992.                                       
          B.   Whether Petitioners' Horse and Rodeo Undertakings Were One             
               Activity                                                               
               Respondent contends that petitioners' horse and rodeo                  
          undertakings were two activities.                                           
               The applicable regulations state that, generally, the most             
          important factors are the degree of organizational and economic             
          interrelationship of the undertakings, the business purpose                 








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