- 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.
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