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After concessions, the only issue for decision is whether
petitioner is liable for penalties for fraud under section
6663(a)1 for the taxable years 1989, 1990, and 1991.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference. Petitioner resided in Panama City, Florida, at the
time he filed his petition. During all the years in issue,
petitioner was married to, and filed joint Federal income tax
returns with, Janice D. Hill.
During the years in issue, petitioner was employed by Bay
Point Yacht and Country Club, Inc. (Bay Point, Inc.), as the
director of property operations. The property operations
department of Bay Point, Inc., through its own employees and
various subcontractors, performed repair, maintenance, and
landscaping work, as well as light construction at Bay Point
Yacht and Country Club.2 The property operations department
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
2Bay Point Yacht and Country Club is a 1,100-acre planned
unit development located in Panama City, Florida. Bay Point
Yacht and Country Club, Inc., served as the developer of Bay
Point Yacht and Country Club and continues to own and operate
some of its ongoing businesses, such as its golf business, its
maintenance and landscaping business, and its marina.
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