- 2 - Penalty Year Deficiency Sec. 6662 1994 $51,294 $10,259 1995 58,018 11,604 1996 45,101 9,020 1997 25,635 5,127 The issues for decision are: (1) Whether the deductions taken by petitioner Robert Schwartz (Mr. Schwartz) and petitioner Diane Schwartz (Mrs. Schwartz) (collectively, petitioners) related to flowthrough losses incurred by Diane Racing International’s (Diane Racing’s) yacht activity were from an activity entered into for profit for 1994, 1995, 1996, and 1997 (years in issue) within the meaning of section 183;1 and (2) whether petitioners are liable for accuracy-related penalties under section 6662.2 FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time they filed the petition, petitioners resided in Islip, New York. 1 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. 2 Petitioners also dispute the allowable portion of their itemized deductions claimed for each of the years in issue. As this issue is computational, we leave it for the parties to compute in accordance with this decision.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