- 2 - Year Deficiency Sec. 6662 1991 $11,543 $2,165 1992 12,634 2,311 1993 12,387 2,489 After concessions,2 the following issues remain for our consideration: (1) Whether petitioners' horse-breeding activity during the taxable years 1991, 1992, and 1993 was engaged in for profit; and (2) whether any underpayment of tax is due to either negligence or intentional disregard of rules or regulations, or a substantial understatement of income tax. FINDINGS OF FACT3 At all times relevant to this case petitioners were husband and wife and resided in West Liberty, Ohio. They filed joint Federal income tax returns for all 3 years at issue. James Dodge (Mr. Dodge) was an attorney and president of Brad Bern Corp. located in Cincinnati, Ohio, during the years at issue. From 1990 through 1993, Mr. Dodge was very active at Brad Bern Corp., working on average 12 hours a day, 4 days a week for the corporation. He lived at petitioners' second home in 2Respondent disallowed unsubstantiated interest deductions of $5,099 and $7,713 in 1991 and 1992, respectively. In addition, respondent determined that petitioners understated interest income in the amount of $66 in 1991. Since petitioners failed to address either of these issues in their brief, we treat this as a concession by petitioners and find for respondent. Theodore v. Commissioner, 38 T.C. 1011, 1041 (1962). 3The stipulation of facts and the attached exhibits are incorporated by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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