Donald Ferry and Sharon Ferry - Page 2

                                                  - 2 -                                                    

                  1 50 percent of the interest due on the amount of the underpayment                       
            attributable solely to fraud.                                                                  
                  All section references are to the Internal Revenue Code in                               
            effect for the years in issue, and all Rule references are to the                              
            Tax Court Rules of Practice and Procedure, unless otherwise                                    
            indicated.                                                                                     
                  The issues for decision are:  (1) Whether petitioners                                    
            underreported their taxable income for the year 1987 in the                                    
            amount of $130,232; (2) whether petitioners underreported their                                
            taxable income for the year 1988 in the amount of $85,231; (3)                                 
            whether the above-mentioned understatements of income for 1987                                 
            and 1988 were attributable to fraud by Donald Ferry (petitioner);                              
            and (4) whether petitioners are liable for an addition to tax                                  
            under section 6661 for 1987 and 1988.             Respondent has conceded                      
            that Sharon Ferry is not liable for the fraud addition.                                        
                                           FINDINGS OF FACT                                                
            Preliminary Matters                                                                            
                  The stipulated facts and exhibits are incorporated by this                               
            reference.                                                                                     
                  When the petition in this case was filed, petitioners                                    
            resided in Newark, Delaware.  Petitioners are husband and wife                                 
            and filed joint Federal income tax returns for the years in                                    
            issue.                                                                                         
                  On their joint Federal income tax return for 1987,                                       
            petitioners reported total income of $6,920 consisting of wages                                





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