Joyce E. Hastings - Page 11




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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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