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penalty under section 66621 in the amount of $18,558.00 for the
taxable year 1990. The issues for decision are as follows:
(1) Whether petitioners are entitled to include an unpaid
commission in the basis of stock sold by petitioner J. Brent
Haymond's wholly owned S corporation;
(2) whether petitioners are liable for the accuracy-related
penalty under section 6662; and
(3) whether petitioner Janis S. Haymond should be relieved
of liability for tax as an innocent spouse pursuant to section
6013(e).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. Petitioners, husband and wife, filed a
joint Federal income tax return for 1990. They resided in
Springville, Utah, at the time they filed their petition.
Petitioner J. Brent Haymond (Mr. Haymond) earned an
undergraduate degree in chemistry and a master's degree in
business administration. He has extensive job experience in
marketing computer technology and in managing information systems
and computer companies in an executive capacity. At some point,
1 Unless otherwise indicated, all statutory 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.
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