- 2 - 1 50 percent of the interest computed on $18,246 at the time of assessment and/or payment of tax. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues remaining for decision are: (1) Whether petitioners failed to report income from thefts on their 1986 return; (2) whether petitioners are liable for the addition to tax for fraud; and (3) whether petitioners are liable for the addition to tax for substantial understatement of liability. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. At the time their petition was filed, petitioners were husband and wife and resided in San Dimas, California. Petitioners were married in November 1983. Petitioner Laura L. Gordon (Mrs. Gordon) was married to Alexander P. Sandoval (Sandoval) from 1975 to 1982. Mrs. Gordon received child support payments in bimonthly amounts of $136 during 1985 and 1986 as a result of her divorce from Sandoval. Petitioners filed a Form 1040, U.S. Individual Income Tax Return, for 1986 showing $42,309 as their adjusted gross income.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011