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After concessions, the issues for decision are:
1. Whether petitioner operated his horse racing and
breeding activity for profit in 1992 and 1993. We hold that he
did not.
2. Whether petitioners are liable for the accuracy-related
penalty for negligence under section 6662 for 1992 and 1993. We
hold that they are not.
Section references are to the Internal Revenue Code for the
years in issue. Rule references are to the Tax Court Rules of
Practice and Procedure. References to petitioner are to Louis A.
Filios.
I. FINDINGS OF FACT
A. Petitioners
Petitioners were married and lived in West Springfield,
Massachusetts, when they filed the petition in this case.1
Petitioner was 92 years old at the time of trial.
Petitioner was born in Italy in 1905 and moved to the United
States when he was 4 years old. He studied engineering for 2
years at Ohio State University. After attending college, he
worked 3 years for Fafner Bearing Co., and later for a company
which produced metal products.
1 Emma L. Filios died on Mar. 12, 1997, after the petition
was filed. Petitioner is executor of the Estate of Emma L.
Filios.
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