John Edward Kerrigan and Joan Marie Kerrigan - Page 3

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            for an addition to tax under section 6651(a)2 for failure to file                          
            a timely Federal income tax return for 1985; and (6) whether                               
            petitioners are subject to an addition to tax under section 6661                           
            as a result of a substantial understatement of their income tax                            
            for 1985.                                                                                  

            Background                                                                                 

                  Some of the facts have been stipulated and are so found.                             
            The stipulation of facts and attached exhibits are incorporated                            
            herein by this reference.  Mr. Kerrigan filed this petition on                             
            behalf of himself and his deceased wife.  At the time of filing,                           
            Mr. Kerrigan resided in Potomac, Maryland.  Petitioners were                               
            married and filed a joint 1985 Federal income tax return.  Mrs.                            
            Kerrigan died on September 15, 1991.                                                       
                  Petitioners filed their 1985 return on April 12, 1989.  On                           
            their return, Mr. Kerrigan listed his occupation as "publisher".                           
            Mr. Kerrigan had been employed for 25 years by the Washington                              
            Post Co. (the Post), where he started as a classified advertising                          
            salesman before eventually becoming a general advertising                                  
            manager.  Mr. Kerrigan resigned from his position in February                              
            1985.  However, after plans for new employment in Chicago failed                           
            to materialize, the Post retained him as a consultant.  Around                             

            2Unless otherwise indicated, all section references 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.                                                                                 




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