Paul F. Dickie - Page 2




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          years in issue.  All Rule references are to the Tax Court Rules             
          of Practice and Procedure.                                                  
               Respondent determined the following deficiencies and                   
          accuracy-related penalties:                                                 
                                        Accuracy-related Penalty                      
          Year      Deficiency               Sec. 6662(a)                             
          1994        $1,095                 $219                                     
          1995      1,050                      210                                    
               The issues we must decide are: (1) Whether the activity of             
          petitioner Paul F. Dickie (petitioner) as a musician was an                 
          activity "not engaged in for profit" within the meaning of                  
          section 183 for the taxable years at issue, (2) whether                     
          petitioner is entitled to a medical expense deduction under                 
          section 213 for taxable year 1994, and (3) whether petitioners              
          are liable for accuracy-related penalties for the taxable years             
          at issue.                                                                   
               Some of the facts have been stipulated are so found.                   
          Petitioner filed a joint income tax return for 1994 in his name             
          and that of his deceased wife, Saundra G. Dickie (Saundra).                 
          Petitioner resided in Prior Lake, Minnesota, at the time his                
          petition was filed.  Petitioner filed a joint income tax return             
          for 1995 with his wife Sherry L. Dickie (Sherry).  Petitioner and           
          Sherry resided in Prior Lake, Minnesota, at the time their                  
          petition was filed.                                                         







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