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fact and opinion, and the additional findings of fact that we
must make are contained in the discussion that follows. After
setting forth certain background information, we shall address
(1) the adjustments made by respondent that are in dispute and
(2) the addition to tax and penalty that are in dispute.
Petitioner bears the burden of proof on all questions of fact.
Rule 142(a).
I. Background
Petitioner maintained his legal residence in Phoenix,
Arizona, at the time the petition in this case was filed.
During 1989, petitioner was a consulting engineer and a
general partner with TQA Associates, a Texas based consulting
firm.
Petitioner is a calendar year taxpayer. Petitioner filed an
Application for Automatic Extension of Time to File U.S.
Individual Income Tax Return for 1989 requesting an extension of
time to August 15, 1990. Petitioner also filed an Application
for Additional Extension of Time to File U.S. Individual Income
Tax Return for 1989 requesting an extension of time to
September 15, 1990. Petitioner filed a U.S. Individual Income
Tax Return, Form 1040, for 1989 (the 1989 tax return), which was
received by the Internal Revenue Service Ogden Service Center on
August 22, 1991. The envelope used by petitioner to mail the
1989 tax return is postmarked August 20, 1991.
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