Reaves Livestock, Inc., et al. - Page 4

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          1984, 1985, 1986, and 1987.  We hold they are for the years for             
          which the understatement is substantial.                                    
               5.   Whether Reaves Livestock is liable for the additions to           
          tax for fraud under section 6653(b)(1) and (2) for 1984 and 1985            
          and section 6653(b)(1)(A) and (B) for 1986 and 1987.  We hold               
          that it is to the extent stated below.                                      
               6.   Whether Linda L. Reaves qualifies as an innocent spouse           
          under section 6013(e).  We hold that she does not.                          
               Unless otherwise indicated, section references are to the              
          Internal Revenue Code.  Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            
                                  FINDINGS OF FACT                                    
          A.   Petitioners                                                            
               1.   Mr. and Mrs. Reaves                                               
               Mr. and Mrs. Reaves are married and lived in Rowland, North            
          Carolina, when they filed the petition in this case.                        
               Mr. Reaves has an eighth grade education.  In 1971, he                 
          formed Reaves Livestock, a North Carolina corporation, the                  
          principal place of business of which is in Rowland, North                   
          Carolina.  Mr. Reaves has been the president and sole shareholder           
          of Reaves Livestock since 1971.  Mr. Reaves has no experience or            
          formal training in bookkeeping or tax matters.                              
               Mrs. Reaves graduated from high school and attended business           
          school for 3 months.  She had no formal training in bookkeeping             






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