- 2 - Penalty Docket No. Year Deficiency Sec. 6662 20185-98 1994 $46,894 $9,379 15968-99 1995 29,264 5,853 15969-99 1995 28,765 5,753 15969-99 1996 53,869 10,774 7007-00 1996 27,032 5,406 The issue addressed in this opinion is whether petitioner Dale A. Rinehart’s (Mr. Rinehart) horse breeding activity was an activity not engaged in for profit for 1994, 1995, and 1996. (A separate opinion will address the issues, previously tried and briefed, of whether petitioner Jeana L. Yeager had cancellation of indebtedness income for 1995, whether petitioner Jeana L. Yeager is entitled to relief pursuant to sections 662 or 6015, and whether petitioners are liable for penalties pursuant to section 6662(a).) FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts, the stipulation of settled issues,3 and the attached exhibits are incorporated herein by this reference. At the time they filed the petitions, petitioners resided in Campbell, Texas. 2 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. 3 All concessions by the parties are accepted by the Court, and they will be incorporated into the decisions to be entered when all other issues are resolved.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