Elizabeth Giles - Page 2

                                        - 2 -                                         
          (1) Whether petitioner’s horse activity was an activity engaged             
          in for profit within the meaning of section 183 during the years            
          in issue; and (2) whether petitioner is liable for accuracy-                
          related penalties under section 6662(a) for 1999 and 2000.                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, the supplemental stipulation of facts,            
          and attached exhibits are incorporated herein by this reference.            
          A.   Background                                                             
               At the time she filed the petition, petitioner resided in              
          Riverside, California.                                                      
               Petitioner is a dentist licensed by the Dental Board of                
          California.  Petitioner operates her own dental practice as a               
          professional corporation, of which she is the sole shareholder.             
          From 1988 through 2003, petitioner’s average annual income from             
          her dental practice was $109,547.  During the years in issue,               
          petitioner reported income from her dental practice of $120,500,            
          $106,250, and $138,250, respectively.                                       



               1(...continued)                                                        
          Internal Revenue Code, as amended, and all Rule references are to           
          the Tax Court Rules of Practice and Procedure.                              
               2  Respondent concedes that petitioner has substantiated all           
          expenses reported on Schedules C, Profit or Loss From Business,             
          for the years in issue.  As a result, respondent concedes that              
          there is no deficiency in 2001 and petitioner is not liable for             
          an accuracy-related penalty relating to that year.                          





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011