T.C. Memo. 1999-208
UNITED STATES TAX COURT
DEAN L. AND CYNTHIA D. SANDERS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24707-96. Filed June 22, 1999.
P, a wealthy businessman, engaged in the activity
of showing and selling cutting horses, incurring
substantial losses during the years in issue, and
during preceding and following years.
Held: Losses disallowed; the activity was not an
activity engaged in for profit; P undertook and carried
on the activity primarily as a hobby.
Held, further, Ps are liable for sec. 6662
accuracy-related penalties.
Thomas L. Overbey and D. Derrell Davis, for petitioners.
Edith F. Moates, for respondent.
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