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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: In these consolidated cases, respondent
determined the following deficiencies and accuracy-related
penalties with respect to petitioners’ Federal income taxes for
the taxable years 1992 through 1995:
Year Deficiency Penalty
Sec. 6662(a)
1992 $10,616 $2,123
1993 23,276 4,655
1994 16,264 3,253
1995 4,521 904
Respondent also disallowed Schedule F deductions of $33,134 for
petitioners’ 1996 taxable year, thereby reducing the net loss
claimed for that year. However, respondent did not determine a
deficiency for 1996. We consider facts with relation to other
years to the extent we deem necessary to redetermine petitioners’
income tax liability for the years before the Court. See sec.
6214(b).
After concessions, the issues remaining for decision are:
(1) Whether petitioners’ cattle-ranching activities
constituted activities not engaged in for profit within the
meaning of section 183, for the taxable years 1992 through 1995;
(2) Whether petitioners’ rental of their personal aircraft
constituted an activity not engaged in for profit within the
meaning of section 183, for the taxable years 1992 and 1993;
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