Austin L. Mitchell and Rebecca A. Mitchell, (2001)
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Austin L. Mitchell and Rebecca A. Mitchell, (2001)
T.C. Memo. 2001-269
UNITED STATES TAX COURT AUSTIN L. MITCHELL AND REBECCA A. MITCHELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 413-00. Filed October 4, 2001. Edgar E. Lim, for petitioner.Thomas C. Pliske, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: Respondent determined deficiencies in petitioners' Federal income taxes of $3,696 for 1995, $5,812 for 1996, and $7,436 for 1997; and accuracy-related penalties under section 6662(a) of $739 for 1995, $1,162 for 1996, and $1,487 for 1997.The issues for decision are: 1. Whether petitioner Austin L. Mitchell operated his farm for profit in 1995, 1996, and 1997. We hold that he did not. 2. Whether petitioners converted their personal residence to rental property in 1995. We hold that they did not. 3. Whether petitioners are liable for accuracy-related penalties under section 6662(a) for negligence or substantial understatement of income tax for 1995, 1996, and 1997. We hold that they are.References to petitioner are to Austin L. Mitchell. References to Mrs. Mitchell are to petitioner Rebecca A. Mitchell. Unless otherwise indicated, section references are to the Internal Revenue Code for the taxable years in issue, and all Rule references are to the Ta...See the full content of this document
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