[Download] "Holmes v. Commissioner of Internal Revenue" by Sixth Circuit U.S. Court of Appeals * eBook PDF Kindle ePub Free

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eBook details

• Title: Holmes v. Commissioner of Internal Revenue
• Author : Sixth Circuit U.S. Court of Appeals
• Release Date : January 01, 1999
• Genre: Law,Books,Professional & Technical,
• Pages : * pages
• Size : 79 KB

Description

The petitioners-appellants, Carolyn S. Holmes ("Carolyn") and Robert E. Holmes ("Robert"), a married couple (collectively referred to as "the petitioners" or "the taxpayers"), have challenged the United States Tax Courts assessment of income tax deficiencies against them for each tax year 1987 through 1991 in the aggregate principal sum of $60,041.51, plus interest, as well as negligence penalties of $528.55 for 1987 and $763.53 for 1988, related to their claimed farming loss deductions. The petitioners, upon their Form 1040 joint personal income tax returns for 1987 through 1989, and their Form 1065 partnership income tax returns for 1990 and 1991, had claimed deductions for losses incurred in operating a farm of approximately 165 acres where they resided and endeavored to grow Christmas trees for the commercial market, harvest timber, plant and cultivate row crops, and engage in the commercial husbandry of trout and catfish. Following audits, the Internal Revenue Service ("the I.R.S." or "the respondent") disallowed the entirety of the petitioners aggregate $123,753 claimed farm loss deductions which were not otherwise excludable from income, on the rationale that the taxpayers did not pursue those agrarian occupations with an actual and honest intent to earn profits. The I.R.S. further imposed the aforementioned additions to tax for negligence because the petitioners had mischaracterized a personal expense of $2,250 in 1987, and two personal expenditures in 1988 which totaled $765.30, as farm-related business expenditures.

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