- 2 - Roger D. Lorence, for petitioners. Stephen R. Takeuchi, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: Respondent determined a Federal income tax deficiency for petitioners’ 2000 taxable year in the amount of $167,221 and a penalty pursuant to section 6662(a) in the amount of $33,444.1 After concessions, the principal issues for decision are: (1) Whether petitioners are entitled to report claimed gains and losses in ordinary income on account of an alleged business of petitioner Lee B. Arberg (Mr. Arberg) as a trader in securities within the meaning of section 475(f)(1); (2) whether petitioners are entitled to deduct various business expenses claimed in connection with the securities trading and/or a consulting business of Mr. Arberg; and (3) whether petitioners are liable for the section 6662(a) accuracy-related penalty for 2000. Certain additional adjustments; e.g., to itemized deductions, are computational in nature and will be resolved by concessions made and our holdings on the foregoing issues. 1 Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended and in effect for the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007