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fraud pursuant to section 6653(b)(1) for 1988 and the penalty for
fraud pursuant to section 6663(a) for 1989 and 1990; or in the
alternative, whether petitioner is liable for the addition to tax
for negligence pursuant to section 6653(a)(1) for 1988 and the
accuracy-related penalty pursuant to section 6662(a) for 1989 and
1990; and
(4) whether respondent is barred by the statute of
limitations from assessing the deficiency and penalty for 1989.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
Background Information
Petitioner Kim Beauchamp (Dr. Beauchamp) resided in Sun
Valley, California, at the time he filed his petition. During
the years in issue,2 petitioner was a physician specializing in
obstetrics and gynecology, and he operated a medical practice as
a sole proprietorship. Petitioner employed various persons in
his medical practice and paid them in cash.
Dr. Beauchamp's Tax Returns
Petitioner prepared his own Federal income tax returns for
1988, 1989, and 1990. Petitioner had no formal training in
2 Unless otherwise indicated, all descriptions refer to the
1988, 1989, and 1990 tax years.
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