Kim Beauchamp - Page 3

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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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