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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”.
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