- 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