- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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