- 2 - 1993 9,683 1,937 1994 10,019 2,004 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, unless otherwise indicated. All dollar amounts are rounded to the nearest dollar, unless otherwise indicated. After concessions by the parties,1 the issues for decision are: (1) Whether petitioners' apple orchard activity and dentistry activity should be treated as one activity or two separate activities for purposes of section 183, and whether petitioners' apple orchard activity was engaged in with the intent to make a profit within the meaning of section 183 during the years at issue. We hold petitioners' apple orchard activity and dentistry activity are two separate activities within the meaning of section 183. We further hold petitioners' apple orchard activity was not engaged in with a profit objective under section 183. (2) Whether petitioners are liable for an accuracy- related penalty pursuant to section 6662(a) for 1992, 1993, and 1 Respondent determined that petitioner was an employee of a denturist from whom he rented an equipped office, rather than a self-employed dentist. In the notice of deficiency, respondent disallowed petitioners' self-employment tax deductions of $1,027, $993, and $747 for 1992, 1993, and 1994, respectively. After trial, respondent conceded that petitioner was self-employed during the years at issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011