- 2 - Respondent determined the following deficiencies, additions to tax, and penalties with respect to petitioners’ Federal income taxes: Addition to Tax Penalty Year Deficiency Section 6651(a) Section 6662(a) 1993 $3,937 $237 $787 1994 6,917 287 1,383 1995 6,330 568 1,266 After concessions by respondent,1 the issues for decision are: (1) Whether petitioners’ horse breeding operation was an activity engaged in for profit within the meaning of section 183(a); (2) whether petitioners’ water and air filtration operation was an activity engaged in for profit within the meaning of section 183(a); (3) whether petitioners are liable for additions to tax for failure to timely file returns under section 6651(a) for the taxable years 1994 and 1995; and (4) whether petitioners are liable for accuracy-related penalties pursuant to section 6662(a) for the years in issue. Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time the petition was filed, petitioners resided in Montgomery, Illinois. 1 Respondent concedes that there is no addition to tax under sec. 6651(a) due from petitioners for 1993. Respondent further concedes $252 of the sec. 6651(a) addition to tax for 1995 due to respondent’s failure to credit petitioners with $5,035 of withheld income taxes.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