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reconsideration of opinion (motion for leave) and petitioners’
motion for reconsideration of opinion and memorandum brief in
support thereof (motion for reconsideration) regarding our
opinion in Rinehart v. Commissioner, T.C. Memo. 2002-71 (Rinehart
II).
Respondent determined deficiencies in and penalties on
petitioners’ Federal income taxes as follows:
Penalty
Docket No. Year Deficiency Sec. 6662
20185-98 1994 $46,894 $9,379
15968-99 1995 29,264 5,853
15969-99 1995 28,765 5,753
15969-99 1996 53,869 10,774
7007-00 1996 27,032 5,406
In Rinehart v. Commissioner, T.C. Memo. 2002-9 (Rinehart I), we
addressed the issue of whether Dale A. Rinehart’s (Mr. Rinehart)
horse breeding activity was an activity not engaged in for profit
for 1994, 1995, and 1996. In Rinehart II, we addressed the
issues of whether petitioners had cancellation of indebtedness
income (COD income) for 1995 and whether petitioners were liable
for penalties pursuant to section 6662(a).2 In Rinehart I and
Rinehart II, we made no findings and reached no conclusions
regarding petitioners’ marital status for Federal income tax
purposes.
2 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.
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Last modified: May 25, 2011