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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
In Rinehart v. Commissioner, T.C. Memo. 2002-9, we addressed the
issue of whether Dale A. Rinehart’s (Mr. Rinehart) horse breeding
activity was an activity not engaged in for profit for 1994,
1995, and 1996. The remaining issues for decision are:2 (1)
Whether petitioners had cancellation of indebtedness income (COD
income) for 1995; and (2) whether petitioners are liable for
penalties pursuant to section 6662(a).3
FINDINGS OF FACT
We incorporate our findings in Rinehart v. Commissioner,
supra, herein by this reference.
On June 21, 1991, Jeana L. Yeager (Ms. Yeager)4 signed a
loan application for $75,000 from Advanta Mortgage Corp. USA
2 The question of whether Jeana L. Yeager is entitled to
relief pursuant to sec. 66 or 6015 is moot because in Rinehart v.
Commissioner, T.C. Memo. 2002-9, we concluded that Mr. Rinehart
engaged in his horse breeding activity for profit.
3 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.
4 We use the term “Ms. Yeager” for convenience only. The
Court makes no findings regarding petitioners’ marital status
during and after the years in issue.
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Last modified: May 25, 2011