- 2 - 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 hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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