Dale A. Rinehart and Jeana L. Yeager, f.k.a. Jeana L. Rinehart, et al. - Page 2




                                        - 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.                                         




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