Charles L. Fields and Barbara S. Fields - Page 4

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                                  FINDINGS OF FACT3                                   
          1.  Overview                                                                
               a.  General                                                            
               Some of the facts have been stipulated and are so found.               
          The stipulations and attached exhibits are incorporated herein by           
          this reference.  Petitioners have been married for the last                 
          33 years, and they resided in Rye, New York, when they filed                
          their petition herein.  They are cash method taxpayers, and they            
          signed and filed 1980, 1981, and 1982 Forms 1040, U.S. Individual           
          Income Tax Return, using the status of "Married filing joint                
          return".  Their 1980, 1981, and 1982 returns reported taxable               
          income of $56,847, $71,010, and $5,550, respectively.  Gross (and           
          adjusted gross) income for the respective years were reported as            
          $86,153, $107,373, and $37,766.  Wages for the respective years             
          were reported as $96,412, $111,652, and $40,166.                            








               3 Petitioner testified at trial.  Based on our observation             
          of petitioner at trial, and following our review of the record as           
          a whole, we conclude that petitioner's uncorroborated testimony             
          is largely unreliable.  See Kraut v. Commissioner, 527 F.2d 1014,           
          1019 (2d Cir. 1975), affg. 62 T.C. 420 (1974); Pepi, Inc. v.                
          Commissioner, 448 F.2d 141, 147 (2d Cir. 1971), affg. 52 T.C.               
          854 (1969); O'Connor v. Commissioner, 412 F.2d 304, 311 (2d Cir.            
          1969), affg. in part and revg. in part T.C. Memo. 1967-174;                 
          Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).                            




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