- 2 - Respondent determined deficiencies of $5,354, $14,599, and $6,159 in petitioner’s Federal income taxes for 1994, 1995, and 1996, respectively, a $21 addition to tax under section 6651(a)(1) for 1995, and accuracy-related penalties under section 6662(a) in the amounts of $1,070.80, $2,919.80, and $1,231.80, respectively, for the years at issue. The issues for decision are: (1) Whether petitioner’s gold mining activity was an activity not engaged in for profit under section 183(a) during the years in question; (2) whether petitioner is entitled to certain deductions attributable to the activity; (3) whether petitioner is liable for an addition to tax under section 6651(a)(1) for 1995; and (4) whether petitioner is liable for accuracy-related penalties under section 6662(a) for 1994, 1995, and 1996.2 Some of the facts were stipulated. Those facts, with the exhibits annexed thereto, are so found and are made part hereof. Petitioner’s legal residence at the time the petition was filed was Georgetown, California. During the years at issue, petitioner worked as a deck engineer and hydraulic equipment operator for a dredging and 2 Numerous other issues were settled by the parties both prior to and during trial involving a child care tax credit, a cost of goods sold deduction, certain unreimbursed employee business expenses, the amount of applicable self-employment tax, and amounts allowable on Schedule C, Profit or Loss From Business, as expenses relating to the business activity at issue.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