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                          
          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.                                        





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011