- 2 -
1990 13,370 3,342
1991 10,963 ---
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure. The issues for
decision are: (1) Whether a horse-breeding activity was an
activity not engaged in for profit; and (2) whether petitioners
are liable for additions to tax pursuant to section 6651(a)(1)
for 1988, 1989, and 1990.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the second supplemental stipulation of
facts, and the attached exhibits are incorporated herein by this
reference. Petitioners Donald Keith Morley (Mr. Morley) and
Rebecca B. Morley, husband and wife, resided in Elizabethton,
Tennessee, at the time they filed their petition. During the
years in issue,1 petitioners had three children. Petitioners
filed their 1988, 1989, and 1990 Federal income tax returns in
April 1990, August 1991, and April 1992, respectively.
Mr. Morley operated a dental practice that was the sole
source of income for his family. His dental practice income
averaged $128,866.
1 Unless otherwise indicated, all descriptions refer to the
1985, 1986, 1987, 1988, 1989, 1990, and 1991 tax years.
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