Terri L and Austin W. Hartsock - Page 2

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          ers’ Federal income tax (tax), as follows:                                  
                                                   Accuracy-Related                   
                 Year          Deficiency          Penalty                            
                 1999            $87,099                $17,420                       
                 2000            104,225                20,845                        
               The issues remaining for decision are:                                 
               (1) Are petitioners entitled for each of the years at issue            
          to deduct gambling losses in excess of the deduction allowed by             
          respondent for each such year?  We hold that they are not.                  
               (2) Are petitioners liable for each of the years at issue              
          for the accuracy-related penalty under section 6662(a)?  We hold            
          that they are.                                                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Petitioners, Terri L. Hartsock (Ms. Hartsock) and Austin W.            
          Hartsock (Mr. Hartsock), resided in Frederick, Maryland, at the             
          time they filed the petition.                                               
               Around 1994, Mr. Hartsock incorporated his business known as           
          The Frederick Painting Company.  Since that time, he and Ms.                
          Hartsock have been employed by that company.                                
               During the years at issue, petitioners did not have a                  
          mortgage loan with respect to their residence and therefore did             
          not have any mortgage loan expenses.  Nor did petitioners have              

               2(...continued)                                                        
          (Code) in effect for the years at issue.  All Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           





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