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Addition to Tax
Year Deficiency Sec. 6651(a)(1)
1986 $2,096 $525
1988 351 88
1989 3,188 797
1990 10,816 2,704
1991 11,961 2,909
1992 5,801 1,448
After concessions by respondent,1 the issues remaining for our
consideration are: (1) Whether petitioner had unreported gross
receipts for her 1986, 1990, and 1991 tax years; (2) whether
petitioner’s horse breeding activity was an activity not engaged
in for profit within the meaning of section 183;2 and (3) whether
petitioner is liable for additions to tax under section
6651(a)(1) for the 1986, 1989, 1990, 1991, and 1992 taxable
years.
FINDINGS OF FACT3
Petitioner Joyce E. Hastings had her legal residence in
Huntington Beach, California, at the time her petition was filed
in this proceeding. After attending Western State College of
1 Respondent conceded the disallowed Schedule C law practice
expenses for 1988, 1989, and 1990. Respondent also conceded
$7,400 of the $15,499 unreported gross receipts adjustment for
1990 and $5,080 of the $22,410 gross receipts adjustment for
1991.
2 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the periods under
consideration. Rule references are to this Court’s Rules of
Practice and Procedure.
3 The parties’ stipulation of facts and exhibits are
incorporated by this reference.
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