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Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1994 $21,603 $4,321
1995 20,881 4,176
1996 18,608 3,722
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
References to petitioner in the singular are to John G.
Parker.
The primary issue for decision is whether significant
expenses that petitioner incurred in purchasing, building,
improving, and flying airplanes were incurred by petitioner in an
activity engaged in for profit.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners resided in
Reno, Nevada.
Since the age of 16, petitioner has been a licensed airplane
pilot. While in the U.S. Air Force, petitioner earned a degree
in aeronautical engineering from the Air Force Institute of
Technology. Upon leaving the Air Force in 1965, petitioner
became a full-time pilot for American Airlines (American) where
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