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FINDINGS OF FACT3
1. Overview
a. General
Some of the facts have been stipulated and are so found.
The stipulations and attached exhibits are incorporated herein by
this reference. Petitioners have been married for the last
33 years, and they resided in Rye, New York, when they filed
their petition herein. They are cash method taxpayers, and they
signed and filed 1980, 1981, and 1982 Forms 1040, U.S. Individual
Income Tax Return, using the status of "Married filing joint
return". Their 1980, 1981, and 1982 returns reported taxable
income of $56,847, $71,010, and $5,550, respectively. Gross (and
adjusted gross) income for the respective years were reported as
$86,153, $107,373, and $37,766. Wages for the respective years
were reported as $96,412, $111,652, and $40,166.
3 Petitioner testified at trial. Based on our observation
of petitioner at trial, and following our review of the record as
a whole, we conclude that petitioner's uncorroborated testimony
is largely unreliable. See Kraut v. Commissioner, 527 F.2d 1014,
1019 (2d Cir. 1975), affg. 62 T.C. 420 (1974); Pepi, Inc. v.
Commissioner, 448 F.2d 141, 147 (2d Cir. 1971), affg. 52 T.C.
854 (1969); O'Connor v. Commissioner, 412 F.2d 304, 311 (2d Cir.
1969), affg. in part and revg. in part T.C. Memo. 1967-174;
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
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Last modified: May 25, 2011