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regulations. Petitioners sought the advice of one accountant
sometime in the 1970s as they were entering the horse breeding
activity. Mr. Reimer also intentionally altered his Federal
income tax withholding in full anticipation of the massive losses
they were claiming in each respective year. We hold that
petitioners are liable for the accuracy-related penalty under
section 6662(a) for each year in issue.
We have considered all arguments by the parties, and, to the
extent not discussed above, conclude that they are irrelevant or
without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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