John Charles Treadaway, Sr. - Page 18




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          we found were paid during that year with respect to the horse-              
          training activities.  We further hold that the underpayment for             
          1995 for purposes of section 6662(a) must be reduced to reflect             
          that holding.                                                               
               On the record before us, we find that, except to the extent            
          stated above, petitioner has failed to establish that he is not             
          liable for the accuracy-related penalty under section 6662(a) for           
          each of the years 1994 and 1995.  Accordingly, except to that               
          extent, we sustain respondent’s determinations that petitioner is           
          liable for the accuracy-related penalty for each of those                   
          years.14                                                                    
               We have considered all of the contentions and arguments of             
          petitioner that are not discussed herein, and we find them to be            
          without merit and/or irrelevant.                                            
               To reflect the foregoing and the concessions of respondent,            


                                             Decision will be entered under           
                                        Rule 155.                                     







               14Because certain of our holdings increase self-employment             
          income for each of the years at issue, correlative adjustments              
          must be made to self-employment tax for each such year.  See                
          supra note 5.                                                               





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