Robert and Joyce Dirkse - Page 2

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          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             
               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.                                      
               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.                            

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