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Respondent determined deficiencies in petitioner’s Federal
income taxes and accuracy-related penalties for 1996 and 1997 as
follows:
Penalty
Year Deficiency Sec. 6662
1996 $11,370 $2,274
1997 16,359 3,271
After a concession by respondent,2 the issues remaining for
decision are as follows:
(1) Whether petitioner engaged in his “health, wealth and
healing ministry” activity for profit within the meaning of
section 183 during each of the years in issue. We hold that he
did not.
(2) Whether petitioner is entitled to deductions for his
“health, wealth and healing ministry” activity for 1997. We hold
that he is not.
(3) Whether petitioner is entitled to a deduction for
charitable contributions for 1997 in an amount greater than that
conceded by respondent. We hold that he is not.
(4) Whether petitioner is liable for the accuracy-related
penalty under section 6662(a) for negligence or intentional
disregard of rules or regulations for each of the years in issue.
2 Respondent concedes that petitioner is entitled to a
deduction for charitable contributions in 1997 in the amount of
$1,500. The extent, if any, to which this concession may have a
tax effect will be determined by the parties in their Rule 155
computation. See sec. 63(c).
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