Thomas L. Hobart - Page 2

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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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