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(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.
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