- 2 -
Respondent determined for 2001 a deficiency in petitioner’s
Federal income tax of $22,5831 and additions to tax under
sections 6651(a)(1), 6651(a)(2), and 6654(a) of $2,944, $1,570,
and $575, respectively.
The issues for decision are whether: (1) Petitioner’s wife2
engaged in her horse barrel-racing activities3 in 2001 with the
primary objective of making a profit; (2) petitioner is liable
for an addition to tax under section 6651(a)(1) for failure to
timely file an income tax return; (3) petitioner is liable for an
addition to tax under section 6651(a)(2) for failure to timely
pay tax; and (4) petitioner is liable for an addition to tax
under section 6654(a) for failure to pay estimated income tax.
Some of the facts have been stipulated and are so found.
The stipulated facts and the exhibits received into evidence are
incorporated herein by reference. At the time the petition in
this case was filed, petitioner resided in Willis, Texas.
Background
During 2001, petitioner was employed in automotive sales and
earned wages of $97,890.64 from Wright Motor Co., Inc. His wife,
1These figures are rounded to the next dollar.
2Petitioner’s wife, Stephanie Cooper, was not listed on the
notice of deficiency, and therefore is not a party to this case.
3Horse barrel-racing is a timed rodeo event in which a
participant must ride a complete circle around each of 3 barrels
and return to the starting point with the fastest time to win.
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