Dora Margaret Benson - Page 3




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          other court, and this opinion shall not be treated as precedent             
          for any other case.                                                         
               Respondent determined deficiencies in petitioner’s Federal             
          income taxes for 2002 and 2003 of $3,011 and $6,942,                        
          respectively.  The central issue for decision is whether                    
          petitioner’s activities were engaged in with a profit objective             
          as contemplated by section 183.2  For the reasons discussed                 
          below, we hold for respondent.                                              
                                     Background                                       
               Some of the facts have been stipulated, and they are so                
          found.  We incorporate by reference the parties’ extensive                  
          stipulation of facts and accompanying exhibits.                             
               At the time the petition was filed, Dora Margaret Benson               
          resided in Colorado.                                                        
               In 2000 petitioner, a registered nurse, won $4 million in              
          the Colorado lottery.  She received $2,720,000, and to honor her            
          late mother, set up a memorial/Christian counseling center, the             
          Lila Osborne Memorial.  In addition to running the memorial,                
          petitioner continued her employment as a nurse.                             
               In 2000 petitioner acquired a building for the memorial.               
          Petitioner’s family helps her with the building without                     
          compensation.  Her sister helps her run the building, and                   


               2  To the extent not discussed herein, other issues are                
          computational in nature and flow from our decision in this case.            






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Last modified: March 27, 2008