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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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