Robert L. and Joanne Tammaro - Page 4




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               Respondent initiated an audit of petitioner’s income tax               
          returns for 1990 through 1992.  The audit was thereafter expanded           
          to include petitioner’s returns for 1993 and 1994.                          
               By notice of deficiency dated August 29, 1997, respondent              
          made the following determinations for the taxable years 1993 and            
          1994:                                                                       
               For 1993, respondent did not determine any deficiency in               
          income tax, but he did determine an addition to tax under section           
          6651(a)(1) in the amount of $303 and an accuracy-related penalty            
          under section 6662(a) in the amount of $756.                                
               For 1994, respondent determined a deficiency in income tax             
          in the amount of $3,784, an addition to tax under section                   
          6651(a)(1) in the amount of $440, and an accuracy-related penalty           
          under section 6662(a) in the amount of $785.                                
               Respondent's deficiency determination was based on the                 
          disallowance of losses claimed from the horse activity.  Although           
          respondent disallowed such losses for both 1993 and 1994, no                
          deficiency in income tax for 1993 resulted therefrom because                
          respondent allowed a carry forward of the unused portion of a net           
          operating loss (NOL) from 1990 that was attributable to                     
          petitioner's accounting practice.  In contrast, respondent did              
          not allow a carry forward to either 1993 or 1994 of losses from             
          the horse activity claimed for 1990, 1991, and 1992.  Again,                
          although respondent disallowed such losses for 1990, 1991, and              






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