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husband and wife who filed a joint Federal income tax
return for each of the years in issue. Respondent issued
two notices of deficiency to petitioners. In the first
notice, respondent determined deficiencies and additions
with respect to petitioners' 1989, 1990, and 1991 returns.
In the second notice, respondent determined deficiencies
and additions with respect to petitioners' 1987 and 1988
returns. Petitioners filed two petitions for redetermina-
tion, one petition to dispute each notice of deficiency.
The Court subsequently consolidated these cases for trial,
briefing, and opinion pursuant to Rule 141. All Rule
references are to the Tax Court Rules of Practice and
Procedure. At the time they filed their petitions in these
consolidated cases, petitioners resided in Calhoun County,
Michigan. All references to petitioner in this opinion are
to Mr. Robert E. Holmes.
Petitioner holds a bachelor's degree in business
administration with minors in economics and small business
management. In 1956, petitioner began working as a sales-
man for State Farm Mutual Insurance Co. (State Farm) in
Battle Creek, Michigan. In 1961, he was promoted to
district sales manager. Petitioner held that position from
the time of his promotion up to and including the time of
trial. Forms W-2, Wage and Tax Statements, issued to
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