Louis A. Filios and Estate of Emma L. Filios, Deceased, Louis A. Filios, Executor - Page 2

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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.            
                                 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.                  

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