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are to the Internal Revenue Code in effect for the year in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
After concessions, the issues for decision are: (1) Whether
petitioner had unreported income in 1988 and, if so, in what
amount and (2) whether petitioner is liable for the fraud
addition to tax for 1988 or, in the alternative, the delinquency
and negligence additions to tax.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petition was filed, petitioner resided in Pensacola,
Florida.
Petitioner met Linda Nelson (Nelson) around 1987, and they
became engaged to marry. After their engagement, petitioner
encouraged Nelson to quit her job so that she would have more
time to make wedding plans. Petitioner promised Nelson that he
would make sure she had access to funds to cover her expenses.
Petitioner and Nelson were married in September 1988. Nelson
filed for divorce in March 1989, and the divorce was final
July 2, 1990.
During 1988, petitioner was employed by Zebrowski and
Associates, Inc. (Zebrowski). Zebrowski was engaged in the
demolition business. Edward Timothy Sullivan (Sullivan) was the
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