- 2 -
1990 19,082 4,639 -- 3,816
1991 11,857 -- -- 2,371
The issues for decision are: (1) Whether petitioner
underreported his income for 1988, 1989, 1990, and 1991, as
determined by respondent; (2) whether petitioner is liable for
the additions to tax for failure to file timely returns for 1988,
1989, and 1990; (3) whether petitioner is liable for the addition
to tax pursuant to section 66611 for an understatement of income
tax on his 1988 Federal income tax return; and (4) whether
petitioner is liable for the accuracy-related penalties pursuant
to section 6662(c) for 1989, 1990, and 1991.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the first and second supplemental
stipulations of facts are incorporated herein by this reference.
Petitioner resided in Ponte Vedra Beach, Florida, at the time he
filed his petition. At all times between December 31, 1987, and
January 1, 1992, petitioner was married to Arlene C. Driggers.
Petitioner filed Federal income tax returns for the taxable
years 1988, 1989, and 1990, on September 9, 1991. Petitioner
timely filed his 1991 Federal income tax return. On his returns
for 1988 and 1989, petitioner reported income from First Coast
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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