MITCHELL v. COMMISSIONER

Docket No. 413-00.

82 T.C.M. 732 (2001)

T.C. Memo. 2001-269

Austin L. Mitchell and Rebecca A. Mitchell v. Commissioner.

United States Tax Court.

Filed October 4, 2001.


Attorney(s) appearing for the Case

Edgar E. Lim, for the petitioner. Thomas C. Pliske, for the 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...

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