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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’s
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