Richard L. and Marjorie A. Pitts - Page 1
















                                 T.C. Memo. 1999-72                                   


                               UNITED STATES TAX COURT                                


                  RICHARD L. AND MARJORIE A. PITTS, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3937-97.              Filed March 10, 1999.                 

               Chester A. Swart, for petitioners.                                     
               Bradley T. Stanek, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               NAMEROFF, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A(b)(3)1 and Rules 180, 181, and           
          182.  Respondent determined a deficiency in petitioners’ 1993               
          Federal income tax in the amount of $3,141 and an accuracy-                 
          related penalty under section 6662(a) in the amount of $628.                
               The issues for decision are:  (1) Whether petitioners                  
          engaged in their horse-related activity during 1993 with the                

          1  All section references are to the Internal Revenue Code                  
          in effect for the year at issue.  All Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  

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