- 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