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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
Procedure.
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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