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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notice of deficiency dated September 10,
1996, respondent determined deficiencies in petitioners' Federal
income taxes and accuracy-related penalties as follows:
Accuracy-related penalty
Year Deficiency Sec. 6662(a)
1992 $74,903 $14,981
1993 121,151 24,230
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision are: (1) Whether petitioner Dean L.
Sanders' Schedule F activity constituted an activity not engaged
in for profit within the meaning of section 183(a), and
(2) whether petitioners are liable for section 6662(a) accuracy-
related penalties on account of negligence or disregard of rules
or regulations.1
1 On brief, petitioners also raise certain issues that depend
on our finding that petitioner Dean L. Sanders' Schedule F
activity was engaged in for profit. Since we do not make that
finding, we need not address those additional issues.
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