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1989 10,097 -- -- $1,761
1990 615 -- -- --
Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect for the years in issue.
After concessions, the issues remaining for decision
are: (1) Whether petitioners realized unreported income
from their activities in connection with their son-in-law's
wholly owned corporation; (2) whether petitioners are
liable for the addition to tax for negligence prescribed by
section 6653(a)(1) with respect to their 1988 return; (3)
whether petitioners are liable for the addition to tax for
substantial understatement of liability prescribed by
section 6661 with respect to their 1988 return; and (4)
whether petitioners are liable for the accuracy-related
penalty prescribed by section 6662 with respect to their
1989 return.
FINDINGS OF FACT
Some of the facts have been stipulated and are so
found. The stipulation of facts, supplemental stipulation
of facts, and exhibits attached to each are incorporated
herein by this reference. Petitioners are husband and
wife who filed a joint Federal income tax return for each
of the years in issue. At the time they filed their joint
petition in this case, petitioners resided in Oklahoma
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