- 2 - 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. When he filed his petition, petitioner resided in Muskogee, Oklahoma. Respondent determined deficiencies in petitioner’s Federal income taxes, additions to tax under section 6651(a)(1), and accuracy-related penalties under section 6662(a) as follows: Additions to Tax Penalties Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1997 $26,097 $6,524.26 $5,146.20 1998 19,113 4,778.25 3,341.80 1999 18,173 1,750.95 3,329.80 The issues for decision are: (1) Whether petitioner engaged in his rodeo and horse-training activity during 1997-99 with the objective of making a profit within the meaning of section 183, (2) whether petitioner is liable for additions to tax under section 6651(a)(1) for filing his tax returns after the due dates, and (3) whether petitioner is liable for accuracy-related penalties under section 6662(a). Background Petitioner is an attorney and partner with the Bonds Matthews Law Firm in Muskogee, Oklahoma. Petitioner’s law practice is concentrated primarily in litigation and plaintiff personal injury law. In 1997, 1998, and 1999, petitioner’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011