- 2 - Respondent determined deficiencies in petitioners’ Federal income taxes and accuracy-related penalties in the following amounts: Year Deficiency Sec. 6662(a) 1996 $39,965 $7,993.00 1997 36,817 7,363.40 After concessions by respondent of the medical expense issues, this Court must decide: (1) Whether petitioners were not engaged in an activity for profit under section 183, (2) whether petitioners were entitled to claimed Schedule F, Profit or Loss From Farming, deductions for the taxable years in issue, and (3) whether petitioners were liable for accuracy-related penalties under section 6662(a) for the taxable years in issue. Some of the facts in this case have been stipulated and are so found. Petitioners’ residence was in Myrtle Creek, Oregon, at the time they filed their petition. Petitioners timely filed Forms 1040, U.S. Individual Income Tax Return, for 1996 and 1997. On the Forms 1040 for both years, petitioner John R. Garbini (petitioner) listed his occupation as rancher. Petitioner Edith M. Garbini’s occupation was listed as housewife. Both petitioners were senior citizens during the taxable years in issue. For each taxable year in issue, petitioners attached to their Form 1040, Schedule F, Profit or Loss From Farming. On Schedule F for 1996, petitioners reported no gross income and deducted expenses in the amount of $127,341,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011