- 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