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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,
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