- 2 - 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) wherePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011