- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011