David W. Hill - Page 2

                                        - 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