Melton R. Boone and Geraldine R. Boone - Page 2

                                                 -  -2                                                    
            Additions to Tax                                                                            
                  Year              Deficiency         Sec. 6651(a)(1)                                  
                  1985               $6,890                        $813                                 
                  1986                7,080                 685                                         
                  1987              5,095                 164                                           
                  1988              3,338                    51                                         
            All issues but one have been settled or conceded by the parties.1                           
            The only issue remaining for decision is whether petitioners are                            
            liable for additions to tax under section 6651(a)(1)2 for failure                           
            to file timely Federal income tax returns for the years 1985                                
            through 1987.                                                                               
                                          FINDINGS OF FACT                                              
                  Some of the facts have been stipulated and are found                                  
            accordingly.  The stipulation of facts and the exhibits attached                            
            thereto are incorporated herein by reference.                                               
                  Petitioners, husband and wife, were residents of Crestview,                           
            Florida, at the time they filed their petition in this case.                                
                  Sometime between 1985 and the time of trial, Melton R. Boone                          
            (petitioner) experienced brain hemorrhaging.  As a result, he                               
            could not safely drive, and his son, Melton R. Boone, Jr., drove                            

            1  With respect to whether petitioner's civil service                                       
            retirement income is taxable, the parties agreed to be bound by                             
            the Veterans' Administration's disability determination.                                    
            Petitioners conceded that respondent's determination of their                               
            Schedule C income for 1985 through 1987 is correct.  Finally,                               
            petitioners conceded at trial that they are liable for the                                  
            addition to tax for failure to file a timely return under sec.                              
            6651(a)(1) for 1988.                                                                        
            2  All section references are to the Internal Revenue Code in                               
            effect for the years in issue, and all Rule references are to the                           
            Tax Court Rules of Practice and Procedure, unless otherwise                                 
            indicated.                                                                                  




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