- 2 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011