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Penalty, I.R.C.
Year Deficiency Sec. 6662(a)
1992 $3,998 $800.00
1993 2,860 572.00
1994 4,852 970.00
1995 3,064 612.80
The issues for decision are whether petitioner’s artist activity
was not engaged in for profit within the meaning of section
183(c) and whether petitioner is liable for accuracy-related
penalties pursuant to section 6662(a).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Richard A. Stasewich (petitioner) resided in Chicago,
Illinois, at the time he filed his petition. Petitioner attended
Northern Illinois University between 1971 and 1977, majoring in
art and minoring in accounting, but he did not graduate. In
1978, petitioner was registered as a certified public accountant
by the University of Illinois, and, in 1983, he was licenced as a
public accountant by the State of Illinois. Between 1978 and
1984, petitioner was employed in various positions utilizing his
accounting background.
During the years in issue, petitioner operated both his
accounting and artist activities out of the same building, where
he also resided. Beginning in 1984, petitioner treated his
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