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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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