Michael G. Bunney - Page 2

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                                             Addition to Tax                          
                    Year        Deficiency       Sec. 6651(a)(1)                      
                    1997      $19,780        --                                       
                    1998      4,980          $186.05                                  
                    1999      21,222         --                                       
               The issue for decision is whether petitioner is entitled to            
          deduct claimed losses reported on Schedule F, Profit or Loss from           
          Farming, from his horse activity for the years in issue.                    
          Petitioner presented neither evidence nor argument concerning the           
          addition to tax and is thus deemed to have conceded that issue.             
               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              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in La Jolla, California, at the time he filed            
          the petition in this case.                                                  
               Petitioner received an undergraduate degree in marketing               
          from San Diego State University.  He received a master of                   
          business administration with a specialization in finance from               
          National University.  Petitioner has been employed with several             
          public and privately held companies since he was 21 with                    
          positions ranging from sales representative to chief operating              
          officer and executive vice president.  Petitioner spent 3 years             

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