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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