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for 1989 pursuant to section 6662; (5) whether petitioners are
liable for additions to tax for the substantial understatement of
tax pursuant to section 6661 for 1986, 1987, and 1988 and for the
penalty pursuant to section 6662(b)(2) for 1990; and (6) whether
petitioners are liable for the addition to tax for failure to
timely file their 1989 joint return pursuant to section 6651(a)(1).
All section references are to the Internal Revenue Code as in
effect for the years in issue, unless otherwise indicated. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference.
Background
Petitioners, husband and wife, resided in Lutherville,
Maryland, at the time they filed their petition. They were married
in 1967 and have one daughter, Nicole.
Mr. Zaban graduated from college in 1967 and subsequently
became involved in illegal gambling and bookmaking activities
(described in detail below). Mrs. Zaban graduated from high school
in 1964 and has no college-level education.
Between 1986 and 1990, Mrs. Zaban was a homemaker and did not
work outside of the home. Mrs. Zaban was the caretaker of
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