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income tax return and the section 6662 accuracy-related penalty.
We sustain respondent’s determination on each contested issue.
FINDINGS OF FACT
Background
Most of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
by this reference.
At the time of filing the petition in this case, petitioner
was a resident of Lemmon, South Dakota. Petitioner was married
during the entire year 1989, the year at issue in this case, to
Mary S. Foust (Mrs. Foust). On October 16, 1990, petitioner
filed a separate individual Federal income tax return for 1989
with the Internal Revenue Service Center at Kansas City,
Missouri, showing zero taxable income and no tax liability.
Pursuant to applications for extension, petitioner had until
October 15, 1990, to file his return.
Petitioner was a practicing Iowa certified public accountant
from 1971 until 1976 and from 1989 through the time of trial.
Petitioner holds a law degree from Drake University, but has not
been admitted to practice law in any jurisdiction.
Petitioner’s Farming-Related Activities
On February 22, 1985, petitioner incorporated Cheyenne; he
acquired all its shares and caused it to become an S corporation.
Petitioner organized Cheyenne for the purpose of farming, by
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