- 3 -
5. Whether petitioners are liable for the accuracy-related
penalty for negligence or intentional disregard of the rules or
regulations for 1989 and 1990. We hold that they are.
Section references are to the Internal Revenue Code in
effect in the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
I. FINDINGS OF FACT
A. Petitioners
1. Mr. and Mrs. Owens
Petitioners Clyde Eugene Owens (Mr. Owens) and Marie W.
Owens (Mrs. Owens) are married and lived in Tallapoosa, Georgia,
when they filed their petition in these cases. They have four
children: Bryan, Dawn, Elaine, and Jason. Dawn was married and
lived with her husband in 1989 and 1990.
At the time of trial, Mr. Owens had been in business for 40
years. He and Mrs. Owens were self-employed in 1989 and 1990.
They operated the Big O Truck Stop and Burger Chick, a fast food
restaurant described further below at paragraph I-B-4.
Mr. and Mrs. Owens owned the land on which the businesses
were located. They hoped to build a motel on their land. They
had a sign that said they would open a motel there in 2001. In
1989 and 1990, they had grapevines and had on their property what
they called a vineyard master house, not otherwise described in
the record. The vines began to die in 1990.
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