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Revenue Code in effect at relevant times, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioner’s Federal
income taxes and additions to tax under section 6651(a)(1) and
(2) and section 6654(a), as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2)1 Sec. 6654(a)
1997 $37,341 $8,176 -- $1,629
1998 20,875 4,696 -- 664
1999 27,562 6,201 -- 967
1 The notice of deficiency did not include an amount for this addition.
After concessions1 by the parties, the issues for decision
are: (1) Whether petitioner’s horse training and breeding
activity during 1997, 1998, and 1999 was an activity not engaged
in for profit within the meaning of section 183; (2) whether
petitioner is entitled to joint filing status for married
individuals under section 1(a)(1) for 1997, 1998, and 1999; (3)
whether petitioner is entitled to long-term capital gain
treatment on the 1997 sale of approximately 700 shares of
securities; and (4) whether petitioner received nonemployee
compensation of $10,800 in 1997.
1 Petitioner concedes that he is liable for the additions
to tax under sec. 6651(a)(1) and sec. 6654(a) for the tax years
in issue. Respondent concedes that petitioner is not liable for
additions to tax under sec. 6651(a)(2) for the tax years in
issue.
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