- 4 - for negligence or intentional disregard of the rules or regulations; (2) whether petitioners are liable for the 1984 addition to tax under section 6651(a)(1); (3) whether petitioners are liable for the additions to tax for substantial understatement of income tax for 1983 and 1984 under section 6661(a); and (4) whether petitioners are liable for an increased rate of interest on deficiencies attributable to tax motivated transactions under section 6621(c). FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference. Petitioners resided in San Bernardino, California, when their petition was filed in this case. Marvin McPike (petitioner) is a retired fire fighter. He was employed for 28 years as a fireman in San Bernardino and 4 years in Colton. He has a high school education. Since graduating from high school, petitioner received no further formal education, except for a few courses in fire science. Petitioner has no previous investment experience other than investing in his personal residence. Kathryn McPike (Mrs. McPike) completed the ninth grade in school. During the years before the Court she was employed as office manager and general clerk for the United Food and Commercial Workers Union. Her responsibilities included typing,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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