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liable for accuracy-related penalties under section 6662(a)1 for
1998, 1999, and 2000 (the years at issue). For 1998, respondent
determined a $1,060 deficiency and $212 accuracy-related penalty.
For 1999, respondent determined a $946 deficiency and $189
accuracy-related penalty. For 2000, respondent determined a
$1,346 deficiency and $284 accuracy-related penalty.
There are two issues for decision. The first is whether
petitioner Austin L. Mitchell (petitioner)2 conducted his farming
activity for profit during the years at issue. We hold he did
not. The second issue is whether petitioners are liable for the
accuracy-related penalty for their underpayments of tax in the
years at issue. We hold they are liable.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated by this reference. Petitioners resided in Salem,
Missouri, at the time they filed the petition.
Petitioner
Petitioner’s family owned and operated a farm (the family
farm) in the Salem area for more than 100 years. Petitioner grew
1All section references are to the Internal Revenue Code in
effect for the years at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
2References to petitioner’s wife are to Mrs. Mitchell.
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