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(10) whether petitioners are liable for the additions to tax
under section 6661 for 1985 through 1987; and
(11) whether Mr. Gandy is liable for an addition to tax
under section 6661 for 1988.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits attached thereto are
incorporated herein by this reference. Petitioners resided in
Ben Wheeler, Texas, at the time they filed their petitions in
these cases. During 1985 through 1989, petitioners were
residents of Van Zandt County, Texas.
Petitioners were married on August 14, 1970. Carolyn S.
Gandy (Mrs. Gandy) attended high school and completed the 10th
grade prior to marrying Mr. Gandy. Mr. Gandy received a
bachelor’s degree in management in 1971 from the University of
Texas at Austin. Petitioners were divorced on June 14, 1988.
Mrs. Gandy moved back into the marital residence in 1991;
however, petitioners remain divorced.
Burnice Gandy is Mr. Gandy's father. In 1947, Burnice Gandy
received a disability discharge from the military. From that
time, Burnice Gandy's income consisted almost exclusively of
military disability and Social Security benefits.
The Nursery
Petitioners established the nursery in 1972. The nursery
property is located 5 miles south of Van, Texas. Petitioners'
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