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I.R.C., and P is not entitled to deduct the losses
therefrom.
Held, further, allowing for concessions, R’s
deficiency determination is upheld.
Held, further, P is liable for the sec.
6651(a)(1), I.R.C., addition to tax for failure timely
to file her 1993 income tax return.
Held, further, P is liable for the sec. 6662(a),
I.R.C., accuracy-related penalty.
Joyce E. Hastings, pro se.
Michael S. Hensley, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined a Federal income tax
deficiency for petitioner’s 1993 taxable year of $22,053.
Respondent also determined an addition to tax of $5,485 pursuant
to section 6651(a)(1) and an accuracy-related penalty of $4,411
pursuant to section 6662(a).
After concessions, the issues remaining for decision are:
(1) Whether petitioner had unreported income from her sole
proprietorship, Joyce Hastings, Attorney at Law, as determined by
respondent, for the 1993 taxable year;
(2) whether petitioner's horse activity constituted an
activity not engaged in for profit within the meaning of section
183, for the 1993 taxable year;
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