- 2 - These deficiencies stem from respondent’s determination that petitioners’ apiary, tree-farming, and rental activities (hereinafter, collectively referred to as petitioners’ Schedule C activities) conducted during 1995 and 1996 (the years in issue) were not activities engaged in for profit, resulting in the disallowance of claimed losses attributable to these activities. The issues for decision are: (1) Whether petitioners’ Schedule C activities were engaged in for profit; and (2) whether petitioners are liable for the section 6662(a) accuracy-related penalties. All section references are to the Internal Revenue Code as in effect for the years in issue. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the exhibits submitted therewith are incorporated herein by this reference. Background Petitioners, husband and wife, resided in Corona, California, on the date they filed their petition contesting respondent’s determinations. For each of the years in issue, petitioners electronically filed joint Federal income tax returns; included as a part of these returns were separate schedules for each of petitioners’ Schedule C activities. These returns were prepared by a paid return preparer, employed by H & R Block.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011