- 2 -
Accuracy-related penalty
Year Deficiency sec. 6662(a)
1991 $16,902 $3,380
1992 21,165 4,233
1993 29,073 5,815
After concessions,1 the issues remaining for decision are
whether petitioners’ horse activity during the years at issue was
an activity not engaged in for profit within the meaning of
section 183(a),2 and whether petitioners are liable for accuracy-
related penalties on account of negligence under section 6662(a)
for the years at issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The first and second stipulations of facts are incorporated in
this opinion by this reference.
The Petitioners
Richard J. and Melodie D. McKeever (petitioners) resided in
Norco, California, on the date they filed their petition in this
case.
1Petitioners conceded that they received $28,000 of
unreported taxable commission income in 1993 and that
respondent’s determinations for 1991 and 1992 are not time barred
by the statute of limitations.
2All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure. Monetary amounts are
rounded to the nearest dollar.
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