- 2 - Penalty Year Deficiency Sec. 6662(a) 1993 $114,257 $22,851 1994 171,550 34,310 1995 189,541 37,908 The issues for our consideration are: (1) Whether petitioners’ solely owned S corporation was engaged in a farming activity for profit under section 183 for the taxable years 1993, 1994, and 1995; (2) whether petitioners are entitled to deduct various amounts claimed as contributions; and (3) whether petitioners are subject to the accuracy-related penalties under section 6662(a).1 FINDINGS OF FACT2 When they filed their petition, Robert and Karen O’Connor resided in Corning, California. Petitioners owned all of the outstanding shares of Omega Waste Management, Inc. (Omega), which was incorporated in December 1989. Omega filed a Form 1120, U.S. Corporation Income Tax Return, for 1989. In 1990, Omega elected S corporation status. During the years at issue, Omega was a recycling broker and consulting firm that arranged for hauling of recyclable materials 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable periods under consideration, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 The parties’ stipulation of facts and exhibits are incorporated herein by this reference.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