Larry T. Cooper - Page 3

                                        - 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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