3
for 1988 and the accuracy-related penalty for substantial
understatement of income tax under section 6662(d) for 1989. We
hold that they are.
The parties agree that computational adjustments will be
required for petitioners' medical expense deduction and Schedule
A miscellaneous deductions and for petitioners' self-employment
income for 1988 and 1989.
References to petitioner are to Clinton N. Bohannon. Unless
otherwise indicated, section references are to the Internal
Revenue Code in effect for the years in issue. Rule references
are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners have lived in the Republic of Panama for 60
years, and they lived there when they filed the petition in this
case. Petitioner worked for the Canal Authority for 18 years.
Petitioners' daughter is Gail Bohannon Wade (Gail Bohannon).
Their former son-in-law is Bob Wade. The Wades lived in
Clermont, Florida, during the years in issue. Scott Bohannon and
Clinton Wade are petitioners' grandsons.
B. Bohannon, S.A.
When he stopped working for the Canal Authority in the mid-
1950's, petitioner formed Bohannon, S.A., a Panamanian
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011