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Addition to Tax and Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6662
1990 $48,003.74 $2,399.77 $9,600.75
1991 61,322.84 -- 12,264.57
1992 72,370.56 -- 14,474.11
1993 104,589.15 -- 20,917.83
1994 42,916.12 -- 8,583.22
1995 25,817.51 -- 5,163.50
After concessions, the issues for decision are: (1) Whether
petitioners’ activity relating to cattle breeding was an activity
not engaged in for profit within the meaning of section 183 for
the years in issue, (2) whether petitioners are liable for an
addition to tax under section 6651(a)(1) in 1990, and (3) whether
petitioners are liable for accuracy-related penalties under
section 6662(a) for the years in issue.
Unless otherwise noted, 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 are so found. We
incorporate by this reference the stipulation of facts,
supplemental, second, and third supplemental stipulations of
facts, and the attached exhibits.
At the time of filing the petition, petitioners resided in
Nashville, Tennessee. Petitioners filed joint returns for the
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