Dennis L. and Margaret J. Knudsen v. Commissioner

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…