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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.
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Last modified: May 25, 2011