Dennis L. and Margaret J. Knudsen, (2008)
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Dennis L. and Margaret J. Knudsen, (2008)
131 T.C. No. 11
UNITED STATES TAX COURT DENNIS L. AND MARGARET J. KNUDSEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 18246-04. Filed November 12, 2008.Ps filed a motion for reconsideration of our Memorandum Opinion in Knudsen v. Commissioner, T.C. Memo. 2007-340 (Knudsen I). In Knudsen I we held that petitioners were not engaged in their animal breeding activity for profit within the meaning of sec. 183, I.R.C. We concluded that we did not need to decide whether Ps met the requirements under sec. 7491(a), I.R.C., to shift the burden of proof to R because the outcome was based on a preponderance of the evidence. In their motion Ps argue that this Court erred in so concluding. Ps also argue for the first time that each factor under sec. 1.183-2(b), Income Tax Regs., is a separate 'factual issue'...See the full content of this document
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