- 11 - Petitioner had unreported income in the amounts of $6,872, $8,099, and $17,330 for the taxable years 1986, 1990, and 1991, respectively. For the years 1986 and 1988 through 1995, petitioner reported net profit or (net loss) from her practice of law, without considering the unreported amounts decided above, as follows: Year Net Profit or (Loss) 1986 $15,914 1988 24,131 1989 35,562 1990 11,594 1991 22,160 1992 31,247 1993 12,444 1994 6,262 1995 (38,571) OPINION The three issues remaining for our consideration are: Whether petitioner’s horse activity was not for profit in any of the taxable years before the Court; whether petitioner’s income from her law practice was understated for 3 taxable years; and whether petitioner is liable for an addition to tax for late filing in any of the taxable years before the Court. We address each issue separately. Horse activity--for profit? Section 183(a) provides that individual taxpayers will not be allowed deductions that are attributable to an “activity * * * not engaged in for profit”.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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