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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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