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under section 6653(b)(1) for the taxable year 1988; (2) whether
petitioner Richard Nelon is liable for additions to tax for
fraudulent failure to file income tax returns under section
6651(f) for the taxable years 1989 through 1991; (3) whether
petitioner Richard Nelon is liable, in the alternative, for a 25-
percent addition to tax under section 6651(a)(1); and (4) whether
petitioner Richard Nelon is liable, in the alternative, for a 5-
percent addition to tax under section 6653(a)(1)(A) and (B) for
1986 and 1987 and section 6653(a)(1) for 1988.
FINDINGS OF FACT2
Petitioners Richard and Brenda Nelon resided in
Rutherfordton, North Carolina, at the time the petition in this
case was filed.3 Richard Nelon (petitioner) left high school
when he was 16 years old, and he is inexperienced in bookkeeping
and financial matters. Petitioner operated a logging business in
the area around Rutherfordton as a sole proprietorship. This
activity was his primary source of income during the years 1986
through 1991. The activity in question was physically demanding
and dangerous work. In practice, petitioner would have to cut
the standing timber, put it on the truck, and deliver the logs to
the yard.
2 The stipulations of facts and the exhibits are
incorporated by this reference.
3 Brenda Nelon is a party only with respect to the 1987 tax
year.
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