- 3 -
1988 and an accuracy-related penalty for 1989 for negligence or
intentional disregard of rules or regulations; (6) whether
petitioners are liable for an addition to tax for the late filing
of their 1988 tax return; and (7) whether petitioners are liable
for additions to tax for 1987 and 1988 and an accuracy-related
penalty for 1989 for substantially understating their income tax
liability.
Petitioners also claim that they had an overpayment of tax
for 1989 due to an error made in the notice of deficiency,
because, as the parties now agree, petitioners' basis in
Resthaven should not be reduced by the amount of dividend
distributions.1
FINDINGS OF FACT2
Petitioners, who during the years in issue were husband and
wife, filed joint Federal income tax returns for the years 1987,
1988, and 1989. Petitioners resided in Wichita, Kansas, at all
times relevant to this case.
Harry D. Bledsoe (petitioner), a high school graduate, began
his career in the cemetery business in 1950. He started as a
1 This Court has jurisdiction to determine the amount of a
potential overpayment to which this petition relates. Sec.
6512(b)(1).
2 The stipulation of facts and the exhibits are incorporated
by this reference.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011