J. Michael and Susan Reimer - Page 29




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          reflected in their inability to realize a profit in a meaningful            
          time period.  Although they followed some business formalities,             
          they failed to plan and project a reasonable method of turning              
          their activity into a profitable enterprise.  The facts and                 
          evidence in this case lead us to conclude that during the years             
          in issue petitioners were unreasonably willing to sustain massive           
          losses in spite of their improbability of profits.                          
               We further find that petitioners failed to prove that their            
          NAS activity was engaged in for profit.  Petitioners offered very           
          little evidence to support their contention that the NAS activity           
          was maintained in a business like manner, that profits were ever            
          sustained, or that they had a plan to make this venture                     
          profitable.                                                                 
               We hold that respondent’s disallowance of petitioners’                 
          losses is sustained.                                                        
          M.   Section 6651(a)(1) Addition to Tax                                     
               Respondent determined additions to tax as a result of                  
          petitioners’ failure to timely file their respective tax returns            
          for tax years 1994 and 1995.  Section 6651(a)(1) imposes an                 
          addition to tax for failure to timely file a tax return.  The               
          addition to tax is equal to 5 percent of the amount of the tax              
          required to be shown on the return if the failure to file is not            
          for more than 1 month.  Sec. 6651(a)(1).  An additional 5 percent           
          is imposed for each month or fraction thereof in which the                  







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