- 24 - 1995. We believe that petitioners enjoyed the ranch lifestyle, were wealthy enough to indulge that lifestyle without too much concern for costs (remember, they did not always open their bank statements), and, at least during their years on the Arkansas ranch, viewed the Schedule F activity as an integral part of that lifestyle (without regard to profitability). 9. Success in Similar Activities Petitioner did not demonstrate success in carrying on any similar activity. See sec. 1.183-(2)(b)(6), Income Tax Regs. E. Conclusion During the years in issue, the Schedule F activity was not an activity engaged in for profit. Respondent’s determination of a deficiency based on that determination is sustained. II. Section 6662(a) Accuracy-Related Penalties Section 6662 provides for an accuracy-related penalty in the amount of 20 percent of the portion of any underpayment attributable to, among other things, negligence or intentional disregard of rules or regulations (hereafter, simply, negligence). Respondent determined section 6662 penalties against petitioners for their negligence in deducting the farm losses shown on the 1992 and 1993 Schedules F. Negligence has been defined as the failure to exercise the due care of a reasonable and ordinarily prudent person under like circumstances. See Neely v. Commissioner, 85 T.C. 934, 947Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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