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MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Walter J. Piszczek petitioned the Court to
redetermine deficiencies in his 1988 through 1990 Federal income
taxes, an addition to tax, and accuracy-related penalties as
follows:
Addition Penalties
Sec. Sec.
Year Deficiencies 6653(a) 6662
1988 $15,910 $796 ---
1989 6,207 --- $1,196
1990 5,310 --- 944
Respondent reflected these determinations in a notice of
deficiency issued to petitioner on May 20, 1994.
We must decide the following issues:
1. Whether petitioner engaged in a Windmill Distillery
activity with an actual and honest objective of making a profit.
We hold he did not.
2. Whether petitioner is entitled to deduct certain other
items in amounts greater than the amounts respondent determined
were proper. We hold he is not.
3. Whether petitioner is liable for the addition to tax for
negligence and accuracy-related penalties for negligence
determined by respondent. We hold he is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the exhibits submitted therewith are
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