Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the taxable years before the
Court, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
After concessions,1 the only remaining issue is whether
petitioners are liable for the accuracy-related penalty under
section 6662 for the taxable years 1990 and 1991.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, supplemental stipulation of facts, and
the exhibits attached thereto are incorporated herein by this
reference.
Petitioners Eric A. and Jane C. Lanigan resided in Winter
Park, Florida, at the time they filed their petition in this
case. Petitioner in the singular will refer to petitioner Eric
A. Lanigan.
During 1989 and 1990, petitioners were having a house built.
The cost of the house exceeded the amount they had budgeted for
it, depleting petitioners' assets. Shortly after they moved into
the house, the builder disappeared, and petitioners received
notice of mechanic's liens on the house in the amount of
approximately $35,000.
1 Petitioners have conceded the deficiencies and the
additions to tax for late filing under sec. 6651(a)(1) for both
1990 and 1991. Respondent has also conceded some income and
deduction items; thus, a recomputation of the deficiencies and
additions will be necessary.
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