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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1990 $9,672 $2,418 --
1991 4,615 1,154 $263
1992 11,216 2,804 492
1993 1,354 339 55
1994 2,486 622 80
Respondent reflected the determinations for 1990 in a notice of
deficiency issued to petitioners on February 20, 1997.
Respondent reflected the other determinations in a notice of
deficiency issued to Mr. Surridge on the same date.
We must decide:
1. Whether petitioners' Arabian horse racing, breeding, and
sales activity was an activity "not engaged in for profit" within
the meaning of section 183. We hold it was.
2. Whether petitioners are liable for the additions to tax
determined by respondent under section 6651(a)(1). We hold they
are.
3. Whether petitioners are liable for the additions to tax
determined by respondent under section 6654. We hold they are.
Unless otherwise stated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact and the exhibits submitted therewith are
incorporated herein by this reference. Petitioners are husband
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