- 2 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011